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COMB v. COMMISSIONER

Docket No. 70932.

18 T.C.M. 400 (1959)

T.C. Memo. 1959-85

David M. Comb and Sally H. Comb v. Commissioner.

United States Tax Court.

Filed April 30, 1959.

Attorney(s) appearing for the Case

David M. Comb, pro se, 1101 Alameda De Las Plugas, Belmont, Calif. Donald G. Daiker, Esq., and Charles W. Nyquist, Esq., for the respondent.

Memorandum Opinion

VAN FOSSAN, Judge:

Respondent determined a deficiency of $2,867.57 in petitioners' income tax for the year 1955, consequent on his holding that certain funds aggregating $18,000, furnished to petitioner by his brother and two other persons to enable him to carry on the business of Thermo Instruments Company, were loans and not investments in the business. The question of the character of the funds furnished to petitioner arises in computing...

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