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HUGH MACRAE LAND TRUST v. COMMISSIONER

Docket No. 108797.

1 T.C. 899 (1943)

HUGH MACRAE LAND TRUST, R. M. SHEPPARD, JULIAN W. MORTON, AND R. O. CROCKETT, TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 13, 1943.

Attorney(s) appearing for the Case

R. O. Crockett, Esq., for the petitioners.

L. W. Creason, Esq., for the respondent.

Respondent originally determined deficiencies in income and excess profits taxes for the year 1937 in the respective amounts of $4,327.07 and $4,326.52. Respondent has conceded error in one determination and now agrees that the deficiencies are not greater than $3,566.73 and $282.34. The only issue involves the question whether the trust is an association taxable as a corporation under section 1001 of the Revenue Act of 1936.

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