COTNAM v. COMMISSIONER

Docket No. 55797.

28 T.C. 947 (1957)

ETHEL WEST COTNAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 31, 1957.


Attorney(s) appearing for the Case

Winston B. McCall, Esq., for the petitioner.

Frederick T. Carney, Esq., for the respondent.


Respondent determined a deficiency in income tax against petitioner for the year 1948 in the amount of $36,985.02. The issues to be decided are (1) whether the sum of $120,000, received by petitioner from an estate as a result of a judgment, is taxable or nontaxable income; (2) whether respondent, in apportioning the $120,000 under section 107 of the Internal Revenue Code of 1939 in computing tax liability, erred in not apportioning...

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