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TRACY v. COMMISSIONER OF INTERNAL REVENUE

No. 6385.

70 F.2d 93 (1934)

TRACY et ux. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

April 11, 1934.

Attorney(s) appearing for the Case

Edward S. Reid, Jr., of Detroit, Mich., for petitioners.

J. H. McEvers, of Washington, D. C. (Sewall Key, C. M. Charest, and Bruce M. Low, all of Washington, D. C., on the brief), for respondent.

Before HICKS and SIMONS, Circuit Judges, and TAYLOR, District Judge.

SIMONS, Circuit Judge.

The only issue presented by this appeal is whether an attempted gift by William R. Tracy to his wife, Helen Gregory Tracy, of a half interest in a trading account with stockbrokers, became effective as against the tax authorities so as to permit one-half of the income of the account to be returned as income of each, and one-half of the interest and losses to be claimed as deductions by each. Separate appeals were originally taken to the Board...

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