PROCTER v. COMMISSIONER

Docket No. 31320.

19 T.C. 387 (1952)

LILLIAN S. PROCTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 4, 1952.


Attorney(s) appearing for the Case

Kenneth M. Spence, Esq., Paul Van Anda, Esq., and Arthur Windels, Esq., for the petitioner.

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


The respondent determined a deficiency in income tax of the petitioner for the year 1947 in the amount of $50,778.13.

The issue is whether the petitioner is entitled to a deduction for the year 1947 of $175,378.44, representing amounts paid by her to or on behalf of her son in consideration for his assignments to her of certain defeasible remainder interests in certain trusts, which interests were divested because of his death in 1947.

FINDINGS OF FACT.<...

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