Worth Steamship Corp. v. Commissioner

OPINION.

Black, Judge-.

Briefly, the issues, as previously stated in greater detail, are (1) whether the net income of $64,379.15 realized from the operation of the S. S. Leslie for the fiscal year period beginning March 14,1941, and ending February 28,1942, is taxable to the Worth Steamship Corporation, and (2) whether the individual petitioners are liable as transferees for the taxes and interest due from the corporation.

As to issue (1), the respondent in his brief opens his argument with the statement that “Where income is derived from property, the basic test for determining who is to bear…