HOILE v. COMMISSIONER

Docket No. 621.

4 T.C.M. 247 (1945)

John Reginald Hoile v. Commissioner.

United States Tax Court.

Entered February 17, 1945.


Attorney(s) appearing for the Case

A. John Pfeiffer, C. P. A., 1316 Washington St., Columbia, S. C., for the petitioner. F. L. Van Haaften, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TURNER, Judge:

The respondent determined deficiencies of $1,576.29 and $2,704.46 in the petitioner's income tax for 1939 and 1940, respectively.

The issues presented are the correctness of the respondent's action (1) in determining that the income received in 1939 and 1940 under a general insurance agency contract was taxable in its entirety to petitioner and not in part to his wife and three children; (2)...

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