RICHARDS v. COMMISSIONER

Docket Nos. 25437, 25438.

19 T.C. 366 (1952)

LORETTO McKENNA RICHARDS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ERNEST V. RICHARDS, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 28, 1952.


Attorney(s) appearing for the Case

Gibbons Burke, Esq., for the petitioners.

Allen T. Akin, Esq., for the respondent.


The petitioners, residents of Louisiana, reported their income, in separate returns, for 1942, 1943, and 1944, on a community property basis. They reported, respectively, their shares of the income of their marital community. The Commissioner determined that each petitioner was taxable, in the taxable years, on one-half of the income of two groups of trusts known as the "Clay Trusts" and the "Burke Trusts"; and that the petitioners were not entitled to deduct in 1943 and...

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