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ESTATE OF SONNABEND v. COMMISSIONER

Docket No. 1838-63.

46 T.C. 382 (1966)

ESTATE OF ABRAHAM M. SONNABEND, DECEASED, ROGER P. SONNABEND, PAUL SONNABEND, STEPHEN SONNABEND, AND LEOPOLD SONNABEND, EXECUTORS, AND ESTHER SONNABEND, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 20, 1966.

Attorney(s) appearing for the Case

Robert J. Richards, Jr., and David Burstein, for the petitioners.

Lawrence A. Wright, for the respondent.

BRUCE, Judge.

Respondent determined a deficiency in income tax for the fiscal year ended August 31, 1958, in the amount of $47,174.36. The sole issues remaining for decision concern the application of section 270 of the Internal Revenue Code of 1954. The issues are (1) whether Abraham M. Sonnabend had allowable deductions attributable to a trade or business carried on by him for 5 consecutive years which in each year exceeded by more than $50,000 the gross...

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