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HARMAN v. COMMISSIONER

Docket Nos. 1145, 1146.

4 T.C. 335 (1944)

SAYERS F. HARMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. C. HENRY HARMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 24, 1944.

Attorney(s) appearing for the Case

George E. H. Goodner, Esq., and Scott P. Crampton, Esq., for the petitioners.

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

Petitioner in Docket No. 1145 contests the determination of a deficiency in income tax for the calendar year 1940 in the amount of $2,663.85. In the deficiency notice the Commissioner added the sum of $16,495.63 to petitioner's net income, describing the adjustment as an "Increase in fiduciary income" and offering therefor the following explanation:

It is held that the loss on sale of coal lands by the Estate of W. F. Harman...

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