TRUST OF GRACE v. COMMISSIONER

Docket No. 18329.

13 T.C. 632 (1949)

TRUST OF NORA GRACE, DECEASED UNDER DEED OF TRUST DATED APRIL 4TH, 1930 BY JOSEPH P. GRACE. JOSEPH P. GRACE AND JOSEPH P. GRACE, JR., TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 24, 1949.


Attorney(s) appearing for the Case

Gerard L. Carroll, Esq., for the petitioners.

John J. Madden, Esq., for the respondent.


OPINION.

LEECH, Judge:

This proceeding involves deficiencies in income tax in the amounts of $3,287.24 and $4,216.79 for the calendar years 1942 and 1943, respectively.

The issues presented are:

(1) Whether the trust created on April 4, 1930, for the benefit of Nora Grace, became four trusts on her death in 1935.

(2) Whether the respondent's notice of deficiency was timely.

In the alternative, if the answer to the first...

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