HUMPHREY v. COMMISSIONER

Docket Nos. 87517, 91584.

39 T.C. 199 (1962)

RALPH L. HUMPHREY AND EVA M. HUMPHREY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 24, 1962.


Attorney(s) appearing for the Case

John E. Boyer, Esq., for the petitioners.

Merrill R. Talpers, Esq., for the respondent.


OPINION.

FAY, Judge:

In these consolidated proceedings, respondent determined deficiencies in income tax of $3,001.92 and $4,017.47 for the calendar years 1957 and 1958, respectively.

The only issues for decision are:

(1) Whether the petitioners, the grantors of a trust created in 1957, are taxable on the income of said trust for the years 1957 and 1958.

(2) Whether the petitioner Ralph L. Humphrey received dividend income...

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