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SILVERMAN v. COMMISSIONER

Docket Nos. 7140-73, 9190-74.

50 T.C.M. 1226 (1985)

T.C. Memo. 1985-515

Harry T. Silverman v. Commissioner.

United States Tax Court.

Filed September 30, 1985.

Attorney(s) appearing for the Case

Michael D. Hess and David B. Stern, 711 Third Ave., New York, N. Y., for the petitioners. David M. Brandes and Robert A. Wagner, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

In these consolidated cases, respondent determined deficiencies in petitioner's 1969 and 1970 Federal income taxes in the amounts of $418,814.94 and $416,135.63, respectively.

After concessions, the issue for our decision is whether capital gains and losses arising from security accounts are to be attributed to petitioner or to his relatives in whose names the accounts were carried.

Findings...

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