Wilkoff v. Commissioner

David L. Wilkoff v. Commissioner.

Wilkoff v. Commissioner

Docket No. 4278.

United States Tax Court

1947 Tax Ct. Memo LEXIS 319; 6 T.C.M. (CCH) 118; T.C.M. (RIA) 47026;

February 7, 1947

Harry Friedman, Esq., for the petitioner. R. Bruce Jones, Esq., for the respondent.

HARRON

Memorandum Findings of Fact and Opinion

HARRON, Judge: The respondent has determined deficiencies in income tax for the years 1940 and 1941 in the respective amounts of $26,268.46 and $164,925.28. The first question is whether the wife and children of petitioner were stockholders in a corporation. Respondent has determined that…