ESTATE OF HALL v. COMMISSIONER

Docket No. 22725.

17 T.C. 20 (1951)

ESTATE OF FRANK HALL, DECEASED, IRVING TRUST COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 17, 1951.


Attorney(s) appearing for the Case

Charles P. Connell, Esq., for the petitioner.

Stephen P. Cadden, Esq., for the respondent.


The respondent has determined a deficiency in the income tax liability of the estate of Frank Hall, deceased, for the year 1945 in the amount of $637.81. The petitioner denies liability for the entire deficiency and, in addition, claims that it is entitled to refund of $383.55 for overpayment of tax.

During the year 1945, the petitioner, as executor and trustee of the estate of Frank Hall, deceased, had a claim for a debt owing...

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