BRADFORD v. COMMISSIONER

Docket No. 70401.

34 T.C. 1059 (1960)

ELEANOR A. BRADFORD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 16, 1960.


Attorney(s) appearing for the Case

William Waller, Esq., and Lawrence Dortch, Esq., for the petitioner.

Jack D. Yarbrough, Esq., for the respondent.


DRENNEN, Judge:

Respondent determined a deficiency in gift tax against petitioner and an addition to the tax under section 291, I.R.C. 1939, for the year 1938 in the respective amounts of $29,025 and $7,256.25. The deficiency and addition to tax were subsequently corrected to $14,850 and $3,712.50, respectively.

The single issue is whether petitioner's substitution of her promissory note in the amount of $205...

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