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LOEB v. COMMISSIONER

Docket No. 3695.

5 T.C. 1072 (1945)

HERBERT A. LOEB, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 21, 1945.

Attorney(s) appearing for the Case

Arnold R. Baar, Esq., for the petitioner.

Gerald W. Brooks, Esq., for the respondent.

The Commissioner determined deficiencies in petitioner's income tax for the calendar years 1939 and 1940 in the respective amounts of $77,953.32 and $20,785.16, by reason of his alleged liability for the payment of tax on dividends paid in those years on corporate stock previously transferred by petitioner in trust for his sons, subject to liens of pledges in favor of third persons, or, in the alternative as to 1939, on account of...

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