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ESTATE OF GOLDSTEIN v. COMMISSIONER

Docket Nos. 60018, 60385.

29 T.C. 931 (1958)

ESTATE OF WILLIAM GOLDSTEIN, DECEASED, MAURICE STERN AND MATYE GOLDSTEIN, CO-EXECUTORS, AND MATYE GOLDSTEIN, SURVIVING WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF HARRY S. GOLDSTEIN, DECEASED, ANNA L. GOLDSTEIN AND EDWIN LETZTER, EXECUTORS, AND ANNA L. GOLDSTEIN, INDIVIDUALLY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 21, 1958.

Attorney(s) appearing for the Case

Maurice Stern, Esq.,1 and Milton H. Stern, Esq., and Bernard S. Berkowitz, Esq.,2 for the petitioners.

Albert Squire, Esq., for the respondent.

The respondent determined deficiencies in income tax for the taxable year 1951 against the Estate of William Goldstein, deceased, et al., in the amount of $56,999.26, and against the Estate of Harry S. Goldstein, deceased, et al., in the amount of $14,679.45.

The sole question for decision is whether the income of L. Goldstein's Sons for the period January 1 through April 21, 1951, was partnership income, distributable 50 per cent to Harry Goldstein and 50 per cent...

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