United States Board of Tax Appeals November 12, 1929, Docket No. 15306. (Hempstead v. Commissioner)

*207OPINION.

Smith :

The errors alleged in the petition relate to the inclusion of certain dividends in petitioner’s taxable income for the years 1920 and 1921 and to the exclusion from taxable income for the year 1921 of a claimed loss on the sale of securities, but the issues before us are (1) whether or not the petitioner made a valid gift to his wife in the year 1920 of certain shares of