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HUMPAGE v. COMMISSIONER

Docket Nos. 26855, 26856.

17 T.C. 1625 (1952)

F. R. HUMPAGE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF CARL G. FISHER, DECEASED, F. R. HUMPAGE AND C. W. CHASE, JR., EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 31, 1952.

Attorney(s) appearing for the Case

George Kennan Hourwich, Esq., for the petitioners.

Rigmor O. Carlsen, Esq., for the respondent.

The respondent determined deficiencies in income tax of the petitioners for the calendar year 1940 as follows:

F. R. Humpage ---------------------------------   $11,059.29
Estate of Carl G. Fisher, Deceased ------------    13,758.64

The proceedings were consolidated for hearing and report.

Both petitioners held stock in a Florida corporation which made distributions to its stockholders in the year 1940. Both reported only a part of the amounts...

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