Finn H. Magnus and Elsie A. Magnus v. Commissioner of Internal Revenue

KALODNER, Circuit Judge.

Finn H. Magnus (“taxpayer”) 1 and Elsie A. Magnus, husband and wife, residents of New Jersey, instituted this action in the Tax Court for a redetermination of a tax deficiency of $14,387.40 assessed for calendar year 1951. The questions presented concern the nature of payments in the amounts of $18,638.-76 and $11,437.22 received by taxpayer in 1951 from a corporation then controlled by him, Magnus Harmonica Corporation (“Magnus”), known, prior to 1947 as International Plastic Harmonica Corporation (“International”). The Tax Court determined that such payments were…