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NICHOLSON v. COMMISSIONER

Docket Nos. 109954, 112307.

3 T.C. 596 (1944)

GEORGE JAMES NICHOLSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GEORGE J. NICHOLSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 10, 1944.

Attorney(s) appearing for the Case

Edgar W. Pugh, Esq., for the petitioner.

Melvin S. Huffaker, Esq., for the respondent.

In Docket No. 109954, the Commissioner determined a deficiency of $1,873.64 in gift tax for 1940, and in Docket No. 112307, deficiencies of $3,550.43, $942.68, and $2,274.25 in income tax for 1937, 1938, and 1939. As to the gift tax deficiency, the petitioner (1) assails the disallowance of two exclusions in determining net gifts for 1935, and (2) asks a determination of the value of the 1935 gifts. As to the income tax deficiencies, he assails (3) the treatment of periodic...

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