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BAYARD v. COMMISSIONER

Docket Nos. 24402, 24403, 24404.

16 T.C. 1345 (1951)

THEODORE R. BAYARD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. A. R. KLIGMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ARNOLD A. BAYARD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 13, 1951.

Attorney(s) appearing for the Case

Abraham L. Shapiro, Esq., for the petitioners.

W. Morgan Hunter, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax for 1943 of $647.48 against Theodore, $439.88 against Kligman, and $2,066.42 against Arnold. The only issue is whether income of a trust which they joined in creating is taxable to the petitioners. The facts have been stipulated.

The petitioners all reside in Philadelphia and filed their returns with the collector of internal revenue for the first district of Pennsylvania...

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