BRENNEN v. COMMISSIONER

Docket Nos. 3567, 3568.

4 T.C. 1260 (1945)

GEORGE K. BRENNEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 30, 1945.


Attorney(s) appearing for the Case

Robert W. Smith, Esq., for the petitioner.

Richard L. Shook, Esq., for the respondent.


These consolidated proceedings involve income tax deficiencies for the years 1940 and 1941 in the respective amounts of $2,255.70 and $14,788.60. The issues are (1) whether respondent erred in treating all gain from the sale of coal and coke as income of the petitioner, rather than one-half as his and one-half that of his wife on a theory of ownership by the entirety; and (2) whether respondent erred in treating all interest from certain bonds and all dividends from certain...

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