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HOFMANN BROS. REALTY CORP. v. COMMISSIONER

Docket No. 93803.

22 T.C.M. 1678 (1963)

T.C. Memo. 1963-320

Hofmann Bros. Realty Corp. v. Commissioner.

United States Tax Court.

Filed December 5, 1963.

Attorney(s) appearing for the Case

Floyd W. Tompkins, 123 S. Broad St., Philadelphia, Pa., for the petitioner. Dennis C. DeBerry, for the respondent.

Memorandum Findings of Fact and Opinion

HOYT, Judge:

The respondent determined deficiencies of $2,938 and $2,103.08 in petitioner's income tax returns for the years 1958 and 1959, respectively. The only issue presented is whether the petitioner is in the "trade or business" of chartering fishing boats within the meaning of sections 162(a) and 167(a) of the Internal Revenue Code of 1954.

Findings...

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