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WATTLEY v. COMMISSIONER

Docket No. 62297.

31 T.C. 510 (1958)

RALPH B. WATTLEY AND JOSEPHINE R. WATTLEY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 11, 1958.

Attorney(s) appearing for the Case

Ralph B. Wattley, pro se.

Clarence P. Brazill, Jr., Esq., for the respondent.

Respondent determined a deficiency in income tax of petitioners for the calendar year 1951 in the amount of $3,439.66.

The principal issue is whether petitioner Ralph B. Wattley is entitled to the benefits of section 107 (a) of the Internal Revenue Code of 1939 with respect to a payment of $30,666.67 received by him in 1951.

FINDINGS OF FACT.

Petitioners, husband and wife, are residents of New York City. They filed joint income tax returns for the...

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