I. L. Van Zandt and Ruth B. Van Zandt v. Commissioner of Internal Revenue

TUTTLE, Chief Judge:

The taxpayers, Dr. Van Zandt and his wife who filed joint income tax returns for the years 1958 and 1959, seek a review of a decision of the Tax Court which denied them the right to deduct from their gross income for the two years in question amounts paid them as rent on the doctor’s offices to two trusts set up by the taxpayers for the benefit of their two children. The facts are stipulated.

On April 29, 1957, Dr. Van Zandt was engaged in the practice of medicine in Fort Worth, Texas, specializing in surgery. In the practice of his profession, among other facilities, he…