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FARRIS v. COMMISSIONER

Docket No. 37691.

22 T.C. 104 (1954)

LEONARD A. FARRIS AND KATHERINE FARRIS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 23, 1954.

Attorney(s) appearing for the Case

Carl T. Smith, Esq., for the petitioners.

Mark Townsend, Esq., for the respondent.

OPINION.

JOHNSON, Judge:

Respondent determined a deficiency of $3,705.22 in petitioners' income tax for 1948. The following issues are presented:

(1) Did the Commissioner err in disallowing $13,085.66 of the $13,678.40 claimed as ordinary and necessary expense of the partnership (Royer-Farris Drilling Company), and allocating the sum disallowed as an offset to the sale price of capital assets in determining the capital gains of the partnership...

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