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ROTHROCK v. COMMISSIONER

Docket Nos. 7781, 7782.

7 T.C. 848 (1946)

WILLOUGHBY J. ROTHROCK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. W. WALTER THRASHER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 23, 1946.

Attorney(s) appearing for the Case

Stephen T. Dean, Esq., for the petitioners.

William H. Best, Jr., Esq., for the respondent.

These proceedings seek redeterminations of deficiencies in gift tax for the year 1941 as follows: Willoughby J. Rothrock (No. 7781), $1,320; and W. Walter Thrasher (No. 7782), $7,920. A penalty for late filing of $330 is also in issue in the case of Willoughby J. Rothrock.

The issue presented is whether a taxable gift ensued from a transaction whereby sons of the respective petitioners became associated with them as partners...

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