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RAKOWSKY v. COMMISSIONER

Docket No. 29509.

17 T.C. 876 (1951)

VICTOR RAKOWSKY AND ELLA J. RAKOWSKY, HUSBAND AND WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 28, 1951.

Attorney(s) appearing for the Case

Paul E. Bradley, Esq., for the petitioners.

Frank M. Cavanaugh, Esq., for the respondent.

The Commissioner has determined a deficiency in petitioners' income tax for the year 1944 of $2,228.35. The deficiency is due to one adjustment made by the Commissioner which is explained in the deficiency notice as follows:

(a) Your taxable net income for 1944 is increased as follows:

Royalty income received and applied to your credit by American
  Cyanamid Company ----------------------------------------------   $10,380.44
Less: Amortization of patent...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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