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MARKS v. COMMISSIONER

Docket No. 59551.

27 T.C. 464 (1956)

LAURENCE M. MARKS AND MARJORIE G. MARKS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 10, 1956.

Attorney(s) appearing for the Case

Victor S. Trygstad, Esq., for the petitioners.

Charles B. Markham, Esq., for the respondent.

OPINION.

RAUM, Judge:

Respondent has determined a deficiency in the income tax of petitioners for the calendar year 1950 in the amount of $14,806.23. The sole issue is whether respondent erred in determining that a payment by petitioner Laurence M. Marks to Shamrock Oil and Gas Corporation in 1950 in the amount of $17,672.08 was not deductible.

All of the facts have been stipulated and are so found.

Petitioners are husband and wife...

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