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HAROLD W. v. COMMISSIONER

Docket Nos. 87982, 93268.

39 T.C. 1107 (1963)

HAROLD W. AND MARY E. CUCKLER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ROYDEN BROWN AND DORIS BROWN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 29, 1963.

Attorney(s) appearing for the Case

Gene W. Reardon, Esq., for the petitioners in Docket No. 87982.

John Corbridge, Esq., for the petitioners in Docket No. 93268.

Jack Morton, Esq., for the respondent.

The Commissioner determined deficiencies against the Cucklers of $1,813.38 for 1954, $38,017.62 for 1955, and $4,006.80 for 1956, and against the Browns, deficiencies of $485.10 for 1954, $39,964.52 for 1955, $636.39 for 1956, and $77.75 for 1957, plus an addition to tax for 1956 of $70.10. The issues for decision are whether Cuckler, Brown & Co., a partnership, received a dividend of $100,000 from the Trinidad National Bank in July 1955 from the transfer of the bank...

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