ESTATE OF JACQUES FERBER v. COMMISSIONER

Docket No. 35462.

22 T.C. 261 (1954)

ESTATE OF JACQUES FERBER, DECEASED, THE PENNSYLVANIA COMPANY FOR BANKING AND TRUSTS, CO-EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 7, 1954.


Attorney(s) appearing for the Case

John B. Leake, Esq., and Stephen T. Dean, Esq., for the petitioner.

Charles J. Hickey, Esq., for the respondent.


The Commissioner determined deficiencies in income tax against the estate of Jacques Ferber of $18,329.36 and $6,551.46 for its taxable years ended February 28, 1947, and February 29, 1948. The issue for decision is whether the estate realized ordinary income or capital gain from auction and bulk sales during the taxable years of furs and fur garments which were part of the decedent's estate.

FINDINGS OF FACT.

Jacques Ferber died on November 30, 1945. His...

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