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PUTCHAT v. COMMISSIONER

Docket No. 1896-64.

52 T.C. 470 (1969)

NATHAN PUTCHAT AND SALLY PUTCHAT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 18, 1969.

Attorney(s) appearing for the Case

Robert B. Alexander, Jr., for the petitioners.

Gerald Backer, for the respondent.

DAWSON, Judge:

Respondent determined a deficiency of $16,370.90 in petitioners' Federal income tax for the year 1959 and of $15.94 for 1960.

Petitioners have conceded certain adjustments made by respondent. The only issue remaining for decision is whether a net amount of $58,433.36 received by petitioner Nathan Putchat in consideration of his release of all rights under a contract constitutes ordinary income or capital gain.

FINDINGS OF FACT...

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