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ESTATE OF PARKER v. COMMISSIONER

Docket No. 110664.

2 T.C.M. 763 (1943)

Estate of Cortlandt Parker, Charles W. Parker and Robert M. Parker, Surviving Trustees, and Charles W. Parker, Surviving Executor of the Last Will and Testament of Cortlandt Parker, deceased v. Commissioner.

United States Tax Court.

Entered September 10, 1943.

Attorney(s) appearing for the Case

John M. Emery, Esq., 744 Broad St., Newark, N. J., for the petitioners. Robert S. Garnett, Esq., for the respondent.

Memorandum Opinion

SMITH, Judge:

This proceeding involves income tax deficiencies for 1937, 1938, and 1939 in the respective amounts of $6,637.68, $8,036.96, and $7,990.30. The deficiencies result from respondent's determination that petitioner is an association taxable as a corporation.

[The Facts]

Petitioner was created in 1909 under a trust agreement entered into by the following named eight children and grandson of Elizabeth...

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