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BURNETT v. COMMISSIONER

Docket No. 54163.

15 T.C.M. 1090 (1956)

T.C. Memo. 1956-210

L. H. Burnett and Harriett R. Burnett v. Commissioner.

United States Tax Court.

Filed September 17, 1956.

Attorney(s) appearing for the Case

R. Carter Scott, Jr., Esq., and Ray R. Shepherd, C. P. A., State-Planters Bank Building, Richmond, Va., for the petitioners. Marion B. Morton, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This proceeding involves a deficiency in income tax for the year 1950 in the amount of $4,195.06.

The sole issue is whether the collection, in 1950, of a claim which petitioner, L. H. Burnett, received among other assets in the liquidation of a corporation in 1945, constituted ordinary income or a long-term capital gain.

The petitioners conceded other issues originally raised in their petition.

Findings...

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