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VANDERBILT v. COMMISSIONER

Docket No. 59266.

16 T.C.M. 1081 (1957)

T.C. Memo. 1957-235

Cornelius Vanderbilt, Jr. v. Commissioner.

United States Tax Court.

Filed December 23, 1957.

Attorney(s) appearing for the Case

John W. Scott, Jr., Esq., and Herrick K. Lidstone, Esq., 15 Broad Street, New York, N. Y., for the petitioner. James J. Quinn, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency in petitioner's income tax for the year 1951 in the amount of $19,319.20.

There are 5 issues for decision: (1) whether petitioner's activities as an author and lecturer constituted the carrying on of a trade or business during the year 1951; (2) whether the Commissioner has the burden of proving that...

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