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SPROULL v. COMMISSIONER

Docket No. 25497.

16 T.C. 244 (1951)

E. T. SPROULL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 30, 1951.

Attorney(s) appearing for the Case

Lewis L. Guarnieri, Esq., for the petitioner.

William R. Bagby, Esq., for the respondent.

Respondent determined a deficiency of $11,550.61 in the petitioner's income tax for 1945.

The sole question is whether respondent was correct in including in petitioner's taxable income for 1945 the amount of $10,500 transferred in trust for petitioner in that year by petitioner's employer, but which was thereafter paid by the trustee to the petitioner in installments in 1946 and 1947 as required by the trust agreement.

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