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DAVISON v. COMMISSIONER

Docket No. 37291.

12 T.C.M. 293 (1953)

Eleanor Sparks Davison (formerly Eleanor Sparks Martin) v. Commissioner.

United States Tax Court.

Entered March 20, 1953.

Attorney(s) appearing for the Case

R. Palmer Baker, Jr., Esq., 25 Broadway, New York, N. Y., for the petitioner. Francis J. Butler, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in petitioner's income tax of $1,431.82 and a negligence penalty of $71.59 for the year 1945.

The assignments of error are as follows:

(a) Respondent, in determining the petitioner's income under Sections 22 (a) and 181 of the Internal Revenue Code for the calendar year 1945 erred in treating an amount of $3,380.00 as income to the petitioner as her distributive...

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