C. W. Stoll v. Commissioner

A partnership of which petitioner was a member loaned money at interest to a group, two members of which were minor sons of the petitioner, to enable them to purchase a cargo boat. The transaction resulted in profit to the participants. Held, the sons' share of the income was not attributable to the petitioner's labor or resources but represents income properly reportable by them. 2. An amount paid by way of compensation for injury to the property of another held not deductible under section 23 (e)(3). 3. Credit for foreign taxes under section 131, Internal Revenue Code, allowed where…