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ESTATE OF GODLEY v. COMMISSIONER

Docket No. 35057.

19 T.C. 1082 (1953)

ESTATE OF IDA S. GODLEY, DECEASED, PAUL F. GODLEY AND JOHN W. YOUNG, JR., COEXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 19, 1953.

Attorney(s) appearing for the Case

Allen S. Hubbard, Esq., and John Westbrook Fager, Esq., for the petitioners.

Stanley W. Herzfeld, Esq., for the respondent.

The respondent determined a deficiency in the income tax of the petitioners' decedent for the taxable year 1947 in the amount of $550.47. The question presented for our decision is whether certain corporate distributions in cash and property made by Southern Natural Gas Company were taxable to the decedent, a stockholder, in full or only to the extent that the fair market value of the distributions was covered by earnings and profits...

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