WILSON v. COMMISSIONER

Docket Nos. 684-62, 686-62.

46 T.C. 334 (1966)

RALPH C. WILSON, SR., AND TENNA K. WILSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. RALPH C. WILSON, JR., AND JANET M. WILSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 13, 1966.


Attorney(s) appearing for the Case

John H. Fildew, for the petitioners.

Ralph W. Eisnaugle, Jr., for the respondent.


FORRESTER, Judge:

Respondent has determined deficiencies in petitioners' income taxes for the calendar year 1957 in the respective amounts set forth after their names:

Ralph C. Wilson, Sr., and Tenna K. Wilson ----------------   $69,539.28
Ralph C. Wilson, Jr., and Janet M. Wilson ----------------    76,409.59

After certain concessions made by the parties, the following issues remain to be decided:

(1) Did the transfer of certain...

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