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ESTATE OF GILL v. COMMISSIONER

Docket No. 84163.

35 T.C. 1208 (1961)

ESTATE OF SARA LOUISE GILL, ROBERT S. GILL, EXECUTOR AND ROBERT S. GILL, INDIVIDUALLY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1961.

Attorney(s) appearing for the Case

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

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

SCOTT, Judge:

Respondent has determined a deficiency in petitioners' income tax for the taxable year 1948 of $24,898.52. The issues raised are whether respondent may reopen the taxable year 1948 under the provisions of sections 1311-1314 of the Internal Revenue Code of 1954, and, if so, the proper amount of income to be included in that year.

FINDINGS OF FACT.

Some of the facts have been stipulated...

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