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COFFEY v. COMMISSIONER OF INTERNAL REVENUE

No. 10804.

141 F.2d 204 (1944)

COFFEY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

March 7, 1944.

Attorney(s) appearing for the Case

C. E. Duncan, of Tavares, Fla., for petitioner.

Fred J. Neuland, Sewall Key, J. Louis Monarch, and Louise Foster, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen. and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and John T. Rogers, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before HUTCHESON, HOLMES, and McCORD, Circuit Judges.

HOLMES, Circuit Judge.

This is a petition for review of a decision of the Tax Court, entered pursuant to an opinion reported in 1 T.C. 579. It involves petitioner's income tax for 1938, and presents three questions: (1) Whether petitioner was taxable upon dividends received on shares of stock that he had endorsed as gifts to his children in previous years; (2) whether he was entitled to deduct sums paid to his children in 1938 as interest...

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