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ANTON v. COMMISSIONER

Docket Nos. 74337, 74336.

34 T.C. 842 (1960)

MARK G. ANTON AND ADELE B. ANTON, ET AL., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 15, 1960.

Attorney(s) appearing for the Case

Samuel J. Foosaner, Esq., for the petitioners.

Arthur Pelikow, Esq., for the respondent.

MURDOCK, Judge:

OPINION.

The Commissioner determined deficiencies in income tax for 1953 of $13,605.96 against Mark G. and Adele B. Anton, and $4,617.86 against the Estate of Thalia E. Graff Smith and Sylvester C. Smith, Jr. The question for decision is whether Mark and Sylvester realized taxable income from a dividend paid to their children on personal holding company stock which they had given to their children prior to the declaration and record...

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