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GIBBON v. COMMISSIONER

Docket No. 31934.

19 T.C. 78 (1952)

JEANNETTE W. FITZ GIBBON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 27, 1952.

Attorney(s) appearing for the Case

Charles A. Davey, Esq., for the petitioner.

S. Jarvin Levison, Esq., for the respondent.

The respondent determined deficiencies in income tax for the calendar years 1946 and 1947 in the amounts of $7,203.18 and $8,981.90, respectively. The question presented is whether dividends paid on 10343/8 shares of the common stock of the Jennison-Wright Corporation are includible in the petitioner's gross income for the calendar years 1946 and 1947. The respondent argues in the alternative that, if the Court finds that the 1947 dividends are not includible in her

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