Tracy v. Commissioner of Internal Revenue

SIMONS, Circuit Judge.

The only issue presented by this appeal is whether an attempted gift by William R. Tracy to his wife, Helen Gregory Tracy, of a half interest in a trading account with stockbrokers, became effective as against the tax authorities so as to permit one-half of the income of the account to be returned as income of each, and one-half of the interest and losses to be claimed as deductions by each. Separate appeals were originally taken to the Board of Tax Appeals from the deficiency assessments of the respondent, but were there consolidated because of identity of issues.…