Rosenwald v. Commissioner of Internal Revenue

PAGE, Circuit Judge.

This is an appeal from the Board of Tax Appeals sustaining the tax deficiency found against petitioner on Ms income tax returns for the years 1919, 1920, and 1921.

The question here is whether the dividends on stocks, interest upon a note, rents from real property, and coupons from Third Liberty Loan bonds, under the circumstances of this case, are taxable as income in the hands of petitioner.

In 1917 petitioner, with his wife, son, and son-in-law organized under the corporation laws of Illinois the Julius Rosenwald Fund (here called fund) for charitable, scientific,…