Sterner v. Commissioner
Opinion
Memorandum Opinion
OPPER, Judge: Respondent determined a deficiency of $425.74 in petitioner's income tax for the calendar year 1947. Although petitioner entered an appearance at the hearing, he offered no evidence.
Petitioner is an individual residing in Forest Hills, New York. He filed an income tax return for the calendar year 1947 with the collector of internal revenue for the third district of New York. Respondent determined a deficiency in petitioner's income tax for that year as follows:
| ADJUSTMENTS | ||
| Net income disclosed by return | $ 8,350.84 | |
| Unallowable deductions and | ||
| additional income: | ||
| (a) Loss from business | $1,114.16 | |
| (b) Interest income | 350.00 | |
| (c) Miscellaneous deduc- | ||
| tions | 500.00 | 1,964.16 |
| Total | $10,315.00 | |
| Nontaxable income and additional | ||
| deductions: | ||
| (d) Taxes | $ 69.70 | |
| Net income as corrected | $10,245.30 | |
| Personal exemptions | * 1,500.00 | |
| Net income subject to normal and | ||
| surtax | $ 8,745.30 | |
| Corrected tax liability | $ 2,102.73 | |
| Tax liability disclosed by return | 1,676.99 | |
| Deficiency in income tax | $ 425.74 | |
Petitioner has failed to establish that the respondent's determination is invalid or erroneous.
There is a deficiency in income tax due from the petitioner for the calendar year 1947 in the amount of $425.74.
Decision will be entered for the respondent.
Footnotes
*. Additional exemption has been allowed for Carl Sterner.↩
Case-law data current through December 31, 2025. Source: CourtListener bulk data.