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PHILLIPS v. COMMISSIONER

Docket Nos. 29723, 29724, 29725.

17 T.C. 1027 (1951)

P. PHILLIPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. HOWARD PHILLIPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. DELLA PHILLIPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 20, 1951.

Attorney(s) appearing for the Case

George E. H. Goodner, Jr., Esq., and Dewey R. Roark, Jr., Esq., for the petitioners.

Newman A. Townsend, Esq., for the respondent.

The Commissioner determined the following deficiencies in the petitioners' income taxes for the calendar year 1946:

P. Phillips --------------------------------   $1,025.04
Della Phillips -----------------------------    1,755.38
Howard Phillips ----------------------------    1,673.77

The issue for decision is whether or not the Commissioner erroneously adjusted each petitioner's net income upward by an amount equaling the amounts for which revolving...

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