TAYLOR v. COMMISSIONER OF INTERNAL REVENUE

No. 235, Docket 24823.

258 F.2d 89 (1958)

Amelia J. TAYLOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided July 14, 1958.


Attorney(s) appearing for the Case

Boris Kostelanetz, New York City (Brozan & Holman, New York City, on the brief), for petitioner.

George W. Beatty, Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and Melva M. Graney, Department of Justice, Washington, D. C., on the brief), for respondent.

Before HINCKS and LUMBARD, Circuit Judges, and DIMOCK, District Judge.


LUMBARD, Circuit Judge.

Petitioner seeks review of a determination by the Tax Court of a $101,694.83 deficiency in her income tax for the calendar year 1947. She contends that the Tax Court erred in taxing her on the profits in 1947 from commodity trading accounts which she maintained in the names of three relatives, and, in the alternative, it should have permitted a credit for taxes paid by two of the relatives on the same profits.

Petitioner, on the death...

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