RUSSELL v. COMMISSIONER

Docket Nos. 90331, 92556.

21 T.C.M. 1178 (1962)

T.C. Memo. 1962-223

Stella Porter Russell v. Commissioner.

United States Tax Court.

Filed September 19, 1962.


Attorney(s) appearing for the Case

Carswell H. Cobb, Esq., 1100 Republic Bank Bldg., Dallas, Tex., for the petitioner. J. C. Linge, Esq., for the respondent.


Memorandum Opinion

BLACK, Judge:

The Commissioner determined deficiencies in income tax of petitioner for the years 1958 and 1959 in the amounts of $22,916.90 and $79,173.37, respectively. In the notice of deficiency for 1958, the Commissioner made the following adjustments:

Taxable income shown on return ........  $58,849.65
Additional income and unallowable
  deduction:
  (a) Income attributed to
        Estate of Lester A.
        Russell...

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