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HAGNER v. COMMISSIONER

Docket Nos. 16352, 16353.

14 T.C. 643 (1950)

FREDERICK H. HAGNER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. CELINA C. HAGNER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 19, 1950.

Attorney(s) appearing for the Case

Frederick H. Hagner, pro se.

D. Louis Bergeron, Esq., for the respondent.

These consolidated proceedings involve deficiencies in individual income tax asserted against each petitioner in the amount of $3,941.31 for the taxable year 1944. The issue in each proceeding is whether $38,000 received in the taxable year as compensation by petitioner Frederick H. Hagner may, for purposes of computation of tax, be allocated over the prior three years under the provisions of section 107 (a) or (d) of the Internal Revenue Code.

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