United States Board of Tax Appeals April 12, 1928, Docket No. 10417 (Richardson v. Commissioner)

*534OPINION.

Rove :

The petitioner’s contention is that he received only $50,000 for his interest in the Palace Hotel property, and hence derived no profit from its sale. He denies the notes were received by Baker on his (petitioner’s) account or that he ever had any interest therein or received any of the proceeds.