AUSTIN v. COMMISSIONER

Docket No. 5751.

6 T.C. 593 (1946)

IDA S. AUSTIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 29, 1946.


Attorney(s) appearing for the Case

Ashley M. Van Duzer, Esq., and Charles O. DeWoody, Esq., for the petitioner.

Thos. F. Callahan, Esq., for the respondent.


This case involves income tax liability for the calendar year 1940. A deficiency of $24,784.28 was determined by the Commissioner. The one question for consideration is whether the petitioner is taxable upon interest paid upon a note which, with interest accrued thereon, petitioner gave to her children. A part of the facts were set forth in a stipulation, and we find them to be as so stipulated. Such parts thereof as are considered pertinent are set forth herein together...

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