HAMILTON v. COMMISSIONER

Docket Nos. 6819 and 6820.

5 T.C.M. 645 (1946)

G. C. Hamilton v. Commissioner. Elizabeth R. Hamilton v. Commissioner.

United States Tax Court.

Entered July 23, 1946.


Attorney(s) appearing for the Case

Theodore H. Roche, Esq., Mills Tower, San Francisco, Calif., for the petitioners. W. J. McFarland, Esq., for the respondent.


Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined a deficiency of $45.91 against each petitioner for 1941. The only issue is whether the Commissioner erred in including in the income of each petitioner one-half of the income of a trust which they established for their daughter, Helen. The facts have been stipulated.

[The Facts]

The petitioners are husband and wife. They reside...

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