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JOHNSON v. COMMISSIONER

Docket No. 52306.

25 T.C. 123 (1955)

BLAINE JOHNSON AND HIS WIFE, EVELYN K. JOHNSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 27, 1955.

Attorney(s) appearing for the Case

Huger Sinkler, Esq., and Albert Simons, Jr., Esq., for the petitioners.

Ralph V. Bradbury, Jr., Esq., for the respondent.

This proceeding involves deficiencies in income taxes of $9,750.50 and $20,021.28 for the respective calendar years 1949 and 1950. Certain adjustments in each year have not been put in issue. The remaining question is whether amounts withheld by finance companies in purchasing from Blaine Johnson trailer notes and security instruments, which amounts were credited to his reserve account on the companies' records, are taxable income...

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