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RICHARDSON v. COMMISSIONER

Docket No. 1204-74.

64 T.C. 621 (1975)

GALE R. RICHARDSON AND GENEVIEVE RICHARDSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 23, 1975.

Attorney(s) appearing for the Case

Walter W. Petroski, for the petitioners.

David J. Duez, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined deficiencies in the amounts of $4,064.47 and $6,635.62 in petitioners' Federal income tax for 1969 and 1970, respectively. The issues for decision are:

(1) Whether funds placed in trust by petitioner Gale R. Richardson's employer during 1969 and 1970 were properly taxable to petitioners during those years. The resolution of this issue, in turn, depends...

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