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ESTATE OF COHEN v. COMMISSIONER

Docket No. 7112.

8 T.C. 784 (1947)

ESTATE OF B. BRASLEY COHEN, DECEASED, WILLIAM F. COLE AND PAULA C. LUBIC, CO-ADMINISTRATORS, AND WILLIAM F. COLE, PAULA C. LUBIC, CAROL LOUISE LUBIC, WILLIAM F. COLE AS GUARDIAN OF THE ESTATE OF BETTY LOU COLE, A MINOR, PAULA C. LUBIC AS GUARDIAN OF THE ESTATE OF ARTHUR MEYRAN LUBIC, A MINOR, AS DISTRIBUTEES OF THE ESTATE OF B. BRASLEY COHEN, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 8, 1947.

Attorney(s) appearing for the Case

Harry C. Cogen, Esq., and A. Calder Mackay, Esq., for the petitioners.

A. J. Hurley, Esq., for the respondent.

Respondent determined a deficiency in income tax against the estate of B. Brasley Cohen for the taxable year May 16 to December 31, 1942, in the amount of $11,142.20. The question is whether the estate is taxable on $27,213.65 of income realized in the taxable year, or whether such income is taxable to the devisees and legatees. Decedent's income tax return was filed with the collector of internal revenue for the sixth district of California at Los Angeles. The case was submitted...

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