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TAVARES v. COMMISSIONER

Docket No. 58576.

32 T.C. 591 (1959)

JOSE TAVARES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 29, 1959.

Attorney(s) appearing for the Case

John J. Egan, Esq., for the petitioner.

Raymond T. Mahon, Esq., for the respondent.

Respondent determined a deficiency in petitioner's In the statement attached to the notice of deficiency this determination was explained as follows:

You were a one-half owner in a winning Sweepstakes ticket that paid $139,391.00. Ticket was in name of your niece, Mary G. Jardine. Only one-half (½) of your share of the ticket (1/4 of total) was reported based on the contention that one-half (½) of your half was owned by your wife, Anna Tavares, a resident...

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