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STRONG v. COMMISSIONER

Docket Nos. 4766, 4767.

7 T.C. 953 (1946)

ERNEST STRONG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JOSEPH W. GRANT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 11, 1946.

Attorney(s) appearing for the Case

Arthur H. Kent, Esq., and Valentine Brookes, Esq., for the petitioners.

Earl C. Crouter, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $825.33 in gift tax for 1940 as to each of these petitioners. The only issue for decision is based upon a plea of res judicata. The facts have been stipulated.

These two petitioners had been engaged in business as partners for some time prior to October 1, 1940. On that day each executed an instrument termed "deed of gift," purporting to convey to his wife one-half...

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