LOUIE v. COMMISSIONER

Docket No. 53341.

15 T.C.M. 586 (1956)

T.C. Memo. 1956-117

Richard H. Louie and Helen L. Louie, Husband and Wife v. Commissioner.

United States Tax Court.

Filed May 15, 1956.


Attorney(s) appearing for the Case

Conrad T. Hubner, Esq., 68 Post Street, San Francisco, Calif., and Ralph A. Taylor, Esq., for the petitioners. Clyde R. Maxwell, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined a deficiency in income tax for 1950 of $17,860.66. The issues raised are principally related to whether petitioner held certain real property as trustee for himself, his brothers, and his sisters, or whether he personally owned an eight-ninths interest. Specifically, the issues are: (1) whether respondent erred in taxing to petitioner all interest received on a mortgage note, rather...

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