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WOFFORD v. COMMISSIONER

Docket Nos. 19857, 20927.

10 T.C.M. 692 (1951)

Tatem Wofford v. Commissioner.

United States Tax Court.

Entered July 31, 1951.

Attorney(s) appearing for the Case

C. Leo DeOrsey, Esq., 204 National Savings & Trust Bldg., Washington 5, D. C. and Harry Friedman, Esq., for the petitioner. S. Earl Heilman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TURNER, Judge:

The respondent determined deficiencies in income tax against petitioner as follows:

Docket No.        Year       Amount

  19857     June 30, 1941  $ 26,357.63
            June 30, 1942    26,449.50
  20927     June 30, 1944   172,018.67

The questions are whether the income from the operation of a resort hotel at Miami Beach, Florida, is taxable to the petitioner alone, or...

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