The Commissioner determined deficiencies in petitioner's income tax of $1,578.33, $3,363.20, $17,442.86, and $42,807.67 for the respective years 1938, 1939, 1940, and 1941. The questions involved are whether the amounts of the profits of Durwood-Dubinsky Bros., formerly Dubinsky Bros., allocated in 1938, 1939, 1940, and 1941 to the petitioner's wife, son, and daughter, respectively, are taxable income to him under section 22 (a), Revenue Act of 1938 and the Internal Revenue...
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