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OVERTON v. COMMISSIONER

Docket Nos. 6226, 6231.

6 T.C. 304 (1946)

CARLTON B. OVERTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GEORGE W. OLIPHANT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 28, 1946.

Attorney(s) appearing for the Case

Harold H. Bowman, Esq., for the petitioners.

Bernard J. Long, Esq., for the respondent.

These proceedings were consolidated for hearing and involve deficiencies of $332.26 and $195.27 in gift tax and penalties of $83.06 and $48.82 for the calendar years 1936 and 1937, respectively, in Docket No. 6226 and a deficiency of $358.02 in income tax for the calendar year 1941 in Docket No. 6231. The issues in Docket No. 6226 are whether certain dividends on class B stock of Castle & Overton, Inc., paid to petitioner's wife are subject to gift tax, and, if so, whether...

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