Amelia J. Taylor v. Commissioner of Internal Revenue

I concur except that I would direct that the payments which accompanied the Newcombes’ income tax returns be set off against petitioner’s liability. A necessary part of the decision that the income was petitioner’s is that the brokerage accounts which earned it were petitioner’s. The payments which accompanied the Newcombes’ income tax returns went direct from those brokerage accounts to the United States Treasury. The Government is saying with one breath “the brokerage accounts were petitioner’s” and with the next “the money which went direct from those brokerage accounts to the Treasury…