DURWOOD v. COMMISSIONER

Docket No. 5749.

6 T.C. 682 (1946)

ED. DUBINSKY DURWOOD, INDIVIDUALLY AND AS SURVIVING HUSBAND, AND ED. DUBINSKY DURWOOD, EXECUTOR OF THE ESTATE OF CELIA D. DURWOOD, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 10, 1946.


Attorney(s) appearing for the Case

Wm. G. Boatright, Esq., and A. Henry Cuneo, C. P. A., for the petitioners.

Gene W. Reardon, Esq., for the respondent.


The Commissioner determined deficiencies in petitioner's income tax of $1,578.33, $3,363.20, $17,442.86, and $42,807.67 for the respective years 1938, 1939, 1940, and 1941. The questions involved are whether the amounts of the profits of Durwood-Dubinsky Bros., formerly Dubinsky Bros., allocated in 1938, 1939, 1940, and 1941 to the petitioner's wife, son, and daughter, respectively, are taxable income to him under section 22 (a), Revenue Act of 1938 and the Internal Revenue...

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