Van Brunt v. Commissioner

*407OPINION.

Littueton :

This proceeding was submitted upon the statements contained in the petition, admitted by the Commissioner in his answer. Petitioner claims that the rent and dividends received by him belonged to his wife and therefore did not constitute taxable income to him. Title to the property from which the rent and dividends in question were received was in petitioner and the properties were held by him. The instrument attempts to assign that portion of petitioner’s income from the sources mentioned to his wife upon her agreement to pay all household and other similar expenses and…