EBNER v. COMMISSIONER

Docket No. 57341.

26 T.C. 962 (1956)

MINNIE R. EBNER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 30, 1956.


Attorney(s) appearing for the Case

Ben Kohler, Jr., Esq., and Joseph J. Fine, Esq., for the petitioner.

Lester R. Uretz, Esq., for the respondent.


This proceeding involves a deficiency in income tax determined against Minnie R. Ebner (hereinafter referred to as petitioner) in the amount of $12,454.77 for the taxable year 1947.

The sole issue to be decided is whether petitioner received, during 1947, more than 30 per cent of the selling price of certain stock sold by her during that year, thereby disqualifying such sale from the installment sale provisions of section 44 (b) of the 1939 Code.

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