ESTATE OF YERBURGH v. COMMISSIONER

Docket No. 6367.

4 T.C.M. 1145 (1945)

Estate of Frances S. Yerburgh, Deceased, Title Guarantee and Trust Company, Ancillary Executor v. Commissioner.

United States Tax Court.

Entered December 27, 1945.


Attorney(s) appearing for the Case

T. P. Mackey, Esq., for the petitioner. William Schmitt, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $304.23 in the petitioner's income tax for the year 1942. The petitioner claims an overpayment of $204.60 by reason of a tax of $213.56 withheld at the source.

The single issue is whether or not the petitioner was engaged in trade or business as contemplated by section 211, Internal Revenue Code.

Findings of Fact

The facts were stipulated. Such portions thereof...

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