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CARTER v. COMMISSIONER

Docket No. 12404-78.

40 T.C.M. 654 (1980)

T.C. Memo. 1980-249

Robert James Carter v. Commissioner.

United States Tax Court.

Filed July 15, 1980.

Attorney(s) appearing for the Case

Robert James Carter, pro se. Nancy J. Bateman, for the respondent.

Memorandum Opinion

WILBUR, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year 1975 in the amount of $195. The only issue for decision is whether $1,073.01 in wages for services rendered during November and December 1974 but not received by petitioner until 1975, were constructively received by petitioner in 1974 within the meaning of section 451.1

All of the facts have been stipulated...

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