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PRICE v. COMMISSIONER

Docket No. 66845.

17 T.C.M. 660 (1958)

T.C. Memo. 1958-124

James D. Price and Florence L. Price v. Commissioner.

United States Tax Court.

Filed June 30, 1958.

Attorney(s) appearing for the Case

John C. Ristine, Esq., 822 Southern Building, Washington, D. C., for the petitioners. James A. Scott, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined deficiencies in income tax for the taxable years 1953, 1954, and 1955 in the amounts of $369.24, $428.54, and $599.66, respectively. The only issue is whether sums received in 1954 and 1955 from sublessees of a business property represent ordinary income, as the Commissioner has determined, or capital gain as the petitioners contend.

Findings of Fact

Petitioners...

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