ABRAHAM v. COMMISSIONER

Docket No. 1122.

3 T.C. 991 (1944)

HERBERT ABRAHAM AND DOROTHY ABRAHAM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 8, 1944.


Attorney(s) appearing for the Case

Milton J. Levitt, Esq., for the petitioners.

Laurence F. Casey, Esq., for the respondent.


This proceeding involves the redetermination of deficiencies of $392.78, $668.88, and $1,041.96 in income taxes for 1938, 1939, and 1940, respectively. The issue is whether certain income is taxable to petitioners or to their children. Petitioners conceded at the hearing that so much of the income as represents interest on personal savings accounts of the husband is taxable to them.

FINDINGS OF FACT.

Petitioners, husband and wife, were at all times here...

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