PERKINS v. COMMISSIONER

Docket No. 92941.

40 T.C. 330 (1963)

IRENE VAVASOUR ELDER PERKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 17, 1963.


Attorney(s) appearing for the Case

Andrew E. Hurley, for the petitioner.

Alvin C. Martin, for the respondent.


SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for the year 1958 in the amount of $1,836.45.

The issues for decision are:

(1) Whether the amount of $6,600 received in 1958 by petitioner from a trust created in her husband's will is includable in her gross income in computing her U.S. Federal income tax or is exempt from such tax under the provisions of article X of the convention between the United States of America...

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