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PENN v. COMMISSIONER

Docket Nos. 24254 and 27550.

11 T.C.M. 776 (1952)

Albert Penn v. Commissioner. Ralph Penn v. Commissioner.

United States Tax Court.

Entered July 28, 1952.

Attorney(s) appearing for the Case

Charles J. Munz, Jr., Esq., and Sidney R. Reed, Esq., both of 608 S. Hill St., Los Angeles 14, Calif., for the petitioners. H. A. Melville, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

These consolidated proceedings involve deficiencies in gift taxes determined by respondent in the amounts of $30,414.64 for 1946 against petitioner Albert Penn, and $9,635.89 for 1946 and $41,161.50 for 1947 against petitioner Ralph Penn. Each of the petitioners claims an overpayment of gift taxes for the years involved.

The various assignments of error present the following questions: (1)...

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