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SWAIM v. COMMISSIONER

Docket No. 3170-66.

50 T.C. 302 (1968)

HARRY L. SWAIM, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 14, 1968.

Attorney(s) appearing for the Case

Robert A. Kohn and Allan B. Solomon, for the petitioner.

W. Gerald Thornton, for the respondent.

OPINION

FAY, Judge:

Respondent determined a deficiency of $14,072.70 in petitioner's income tax for the taxable year 1962.

Petitioner failed to discuss on brief certain issues raised in the pleadings. We therefore conclude that he abandoned these issues. The issue left for decision is whether petitioner received income under section 453(d)(1)1 in the taxable year 1962 when the Jefferson Circuit Court in Kentucky...

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