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SWITOW v. COMMISSIONER

Docket Nos. 42796, 42797.

15 T.C.M. 291 (1956)

T.C. Memo. 1956-63

H. R. Switow and Florence K. Switow, husband and wife v. Commissioner. Sam J. Switow and Irma J. Switow, husband and wife v. Commissioner.

United States Tax Court.

Filed March 16, 1956.

Attorney(s) appearing for the Case

Frank A. Garlove, Esq., 600 Marion E. Taylor Building, Louisville, Ky., and Irwin G. Waterman, Esq., for the petitioners. John L. Carey, Esq., and Gene W. Reardon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These consolidated proceedings involve deficiencies in income tax for the year 1948 as follows:

  Docket No.               Deficiency

    42796................  $4,949.41
    42797................   7,738.70

The contested issue is whether the amount received by petitioners on the determination of their contractual arrangements with the Anderson Theatrical Enterprises is taxable as ordinary income...

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