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BRADFORD v. COMMISSIONER

Docket No. 70400.

34 T.C. 1051 (1960)

J. C. BRADFORD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 16, 1960.

Attorney(s) appearing for the Case

William Waller, Esq., and Lawrence Dortch, Esq., for the petitioner.

Jack D. Yarbrough, Esq., for the respondent.

OPINION.

DRENNEN, Judge:

Respondent determined a deficiency in petitioner's income tax for the year 1946 in the amount of $40,974.62.

The issues raised by the pleadings are: (1) Whether petitioner received ordinary income in the amount of $50,000 in the year 1946 as a result of a transaction in which a $100,000 promissory note signed by his wife was discharged for $50,000; and (2) whether the assessment and collection of a deficiency for the...

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