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ESTATE OF BILLINGS v. COMMISSIONER

Docket No. 17740.

8 T.C.M. 1044 (1949)

Estate of Lydia M. Billings, Deceased, L. R. Billings and Geraldine Billings, Co-Executors v. Commissioner.

United States Tax Court.

Entered December 6, 1949.

Attorney(s) appearing for the Case

Harrison H. Simpson, Esq., and George E. Oefinger, C. P. A., 405 Montgomery St., San Francisco, Calif., for the petitioner. T. M. Mather, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined a deficiency in estate tax in the amount of $16,168.71. The sole issue for decision is whether 40 acres of real property of a value of $9,000 and 163 8/10 shares of stock of a value of $250 per share are properly includible in the decedent's gross estate. The facts are found from the stipulation of facts and attached exhibits.

Findings of Fact

Petitioner is an...

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