DI BORGO v. COMMISSIONER

Docket No. 47528.

23 T.C. 76 (1954)

VALERIE NORRIE POZZO DI BORGO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 15, 1954.


Attorney(s) appearing for the Case

Walter A. Keane, Esq., for the petitioner.

Donald J. Fortman, Esq., for the respondent.


Respondent determined a deficiency in the amount of $531.03 for the taxable year 1949, based upon a recomputation of foreign tax credits claimed in petitioner's income tax return for that year. Petitioner concedes the correctness of this determination but asserts an overpayment of income tax for the same year in the amount of $2,278.04 on the ground that she is entitled to a deduction for trustee's commissions in excess of the amount claimed in her return.

Petitioner...

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