ESTATE OF SMITH v. COMMISSIONER

Docket No. 94457.

22 T.C.M. 1641 (1963)

T.C. Memo. 1963-312

Estate of Cecil W. Smith, Deceased, Toby Y. Thompson, Administrator v. Commissioner.

United States Tax Court.

Filed November 25, 1963.


Attorney(s) appearing for the Case

Edward M. Gerrity, 160 W. State St., Sycamore, Ill., for the petitioner. Helen A. Viney for the respondent.


Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in the income tax of petitioner for the years and in the amounts as follows:

  Year             Deficiency

  1952...........  $   91.97
  1953...........   1,207.85
  1954...........   2,015.31

The sole issue is whether petitioner is taxable on a fifty percent share of the distributable income of a partnership for the taxable years 1952,...

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