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RYAN v. COMMISSIONER

Docket No. 15228.

15 T.C. 209 (1950)

JEAN (JOHN) E. L. RYAN AND YVONNE RYAN, HIS WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 7, 1950.

Attorney(s) appearing for the Case

Robert Ash, Esq., and Carl F. Bauersfeld, Esq., for the petitioners.

Paul P. Lipton, Esq., for the respondent.

Respondent has determined a deficiency in petitioners' income tax liability for the taxable year ending December 31, 1941, in the amount of $9,939.37. The deficiency results from respondent's determination that income in the amount of $17,808.48 reported as fiduciary income by the estate of John Ryan should be taxable instead to petitioners.

The proceeding has been submitted upon the pleadings, oral testimony, and a stipulation...

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