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SATZ v. COMMISSIONER

Docket No. 1050-74.

35 T.C.M. 1578 (1976)

T.C. Memo. 1976-344

Joel Satz and Marie Ellen Satz v. Commissioner.

United States Tax Court.

Filed November 11, 1976.

Attorney(s) appearing for the Case

Hyman Friedman, 1 Penn. Pl., New York, N.Y., for the petitioners. Michael P. Casterton, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

  Year             Deficiency

  1968............ $5,773.32
  1969............  7,166.21

Due to concessions, the sole issue remaining for decision is whether petitioner Marie Ellen Satz, a cash basis taxpayer, realized additional income of $17,500 in both 1968 and 1969 by receipt of certain payments...

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