Hill v. United States

GREEN, Judge.

The only question involved in the case is whether a certain transfer of securities made by the plaintiff to his wife was made in good faith and was a bona fide sale. The Commissioner of this court appointed to hear the evidence found that at the time of the transfer there was no agreement or understanding as to the repurchase of the securities by plaintiff from his wife. After carefully reviewing the evidence, we have adopted this finding. The evidence shows that the purpose of plaintiff in making the sale to his wife was to establish a loss and thereby reduce his income tax, and…