R. C. COFFEY v. COMMISSIONER

Docket No. 105452.

1 T.C. 579 (1943)

R. C. COFFEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 12, 1943.


Attorney(s) appearing for the Case

Frederick L. Pearce, Esq., for the petitioner.

F. L. Van Haaften, Esq., for the respondent.


This proceeding involves a deficiency of $29,171.28 in petitioner's income tax for 1938. The issues are:

(1) Whether petitioner is taxable on the dividends received by him in 1938 on shares of stock which he claims to have given to his minor children in prior years;

(2) Whether petitioner is entitled to deduction of amounts paid to his children in 1938 as interest for the use of the dividends which he received in 1937 on the shares, certificates for which...

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