The Commissioner has determined deficiencies in petitioner's income tax for the taxable years ending December 31, 1943, 1944, and 1945 in the amounts of $48,992.18, $64,082.01, and $127,626.15, respectively.
The sole issue is whether the estate of C. Jim Stewart was in the process of administration during the years 1942 to 1945, inclusive, so that the income reported by the estate in such years was taxable to it rather than to the beneficiary, the petitioner herein...
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