Choynski v. Commissioner

OPINION.

We are satisfied that the interest in question was received by the petitioner as trustee or agent for his mother, his sister, and certain clients, and that it was accounted for and paid over to those persons in the years in which he received it. In our opinion the respondent erred in including any part of such interest in the petitioner’s income for 1920 and 1921, and we so hold.

Judgment will be entered wnder Bule 50.