ESTATE OF RUSSELL v. COMMISSIONER

Docket No. 556-64.

47 T.C. 8 (1966)

ESTATE OF GEORGE E. RUSSELL, DECEASED, MARIE M. RUSSELL, EXECUTRIX, AND MARIE M. RUSSELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

October 7, 1966.


Attorney(s) appearing for the Case

Lenahan O'Connell, for the petitioners.

Robert B. Dugan, for the respondent.


OPINION

DAWSON, Judge:

Respondent determined a deficiency in the income tax of petitioners for the year 1959 in the amount of $7,546.71.

Petitioners do not contest respondent's disallowance of a medical deduction of $152.20. Consequently, the only issue for decision is whether petitioners realized ordinary income or capital gain upon the receipt in 1959 of $31,344.56 representing the proceeds of certain...

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