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ESTATE OF SPARKS v. COMMISSIONER

Docket No. 14116.

7 T.C.M. 914 (1948)

Estate of Marshall Rowe Sparks, Deceased, By L. Clay Sparks, Executor v. Commissioner.

United States Tax Court.

Entered December 1, 1948.

Attorney(s) appearing for the Case

J. C. McCoy, Esq., 1320 Hudson Ave., Longview, Wash., for the petitioner. R. G. Harless, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

The Commissioner determined a deficiency of $30,032.68 in decedent's income tax for 1943 by adding to income reported the profits of a hardware business for April-December 1943, under the view that decedent's formal transfer of this business and its assets on April 1, 1943, to his children was lacking in substance because decedent retained management and control...

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