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CULBERTSON v. COMMISSIONER

Docket Nos. 22757, 22758.

14 T.C. 1421 (1950)

A. B. CULBERTSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. RUBY CULBERTSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1950.

Attorney(s) appearing for the Case

R. B. Cannon, Esq., for the petitioners.

John W. Alexander, Esq., for the respondent.

Respondent determined deficiencies in income tax for the year 1945 in the following amounts:

Docket No.               Petitioner          Deficiency

22757                  A. B. Culbertson       $4,674.16
22758                  Ruby Culbertson         4,799.16

The proceedings were consolidated for hearing and decision.

The sole issue is: Did petitioners realize ordinary income, as determined by respondent, or long term...

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