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JERGENS v. COMMISSIONER

Docket No. 30176.

17 T.C. 806 (1951)

ANDREW JERGENS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 21, 1951.

Attorney(s) appearing for the Case

William R. Seaman, Esq., for the petitioner.

John O. Durkan, Esq., for the respondent.

The respondent determined a deficiency in income tax for the taxable years 1944 and 1945, as follows:

Year                                      Deficiency

1944 ----------------------------------   $44,352.34
1945 ----------------------------------     7,047.72

The question is whether or not the petitioner is entitled to five deductions claimed by him and disallowed by the respondent in the two years.

FINDINGS OF FACT.

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