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MONTGOMERY v. COMMISSIONER

Docket No. 36040.

23 T.C. 105 (1954)

W. T. S. MONTGOMERY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 22, 1954.

Attorney(s) appearing for the Case

William T. Rogers, Esq., and John W. Donahoo, Esq., for the petitioner.

A. E. Carpens, Esq., for the respondent.

The Commissioner determined a deficiency of $5,529.66 in income tax for 1946 and one of $6,335.51 for 1947. The only issue for decision is whether the income of the Jacksonville Blow Pipe Company is taxable in its entirety to the petitioner.

FINDINGS OF FACT.

The petitioner filed his separate returns for the taxable years with the collector of internal revenue for the district of Florida.

The petitioner operated the Jacksonville Blow Pipe Company...

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