RICHARDS v. COMMISSIONER

Docket No. 40928.

13 T.C.M. 1191 (1954)

T. C. Memo. 1954-240

John Ruskin Richards v. Commissioner.

United States Tax Court.

Filed December 30, 1954.


Attorney(s) appearing for the Case

George O. Philips, Esq., for the petitioner. George J. Rabil, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $74,041.72 in income tax for 1947. The issues for decision are whether income of a partnership is taxable to the petitioner instead of to his wife and whether a loan to his brother and wife became worthless in 1947.

Findings of Fact

The petitioner filed his individual return for 1947 with the collector of internal...

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