ESTATE OF SILVERMAN v. COMMISSIONER

Docket No. 85905.

22 T.C.M. 694 (1963)

T.C. Memo. 1963-146

Estate of Herman Silverman, Deceased, Jeanette Sternlieb, Executrix, and Rebecca Silverman, Surviving Wife v. Commissioner.

United States Tax Court.

Filed May 28, 1963.


Attorney(s) appearing for the Case

Burton A. Schenley, 450 Seventh Ave., New York, N. Y., for the petitioners. Gerald J. Robinson, for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income tax for the years 1955, 1956, and 1957 in the respective amounts of $3,388.28, $2,596.08, and $2,797.54, which are contested by petitioners Rebecca Silverman and the Estate of Herman Silverman, who is hereinafter referred to as decedent. The sole issue is whether amounts distributed to decedent by a corporation of which he was majority stockholder in exchange...

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