DOYLE v. COMMISSIONER

Docket No. 663.

3 T.C. 1092 (1944)

RICHARD S. DOYLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 17, 1944.


Attorney(s) appearing for the Case

Richard S. Doyle, Esq., and Stanley Worth, Esq., for the petitioner.

Philip A. Bayer, Esq., for the respondent.


The Commissioner determined a deficiency of $5,860.25 in income tax for 1938, as the result of including in petitioner's gross income $20,955.61 received by his wife and minor sons in payment of rights petitioner had theretofore given them in a contract.

FINDINGS OF FACT.

The petitioner, a resident of Bethesda, Maryland, filed his 1938 income tax return at Baltimore, Maryland. The return was on the cash basis. His wife, Anne, filed a separate income tax...

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