APPLEBY v. COMMISSIONER

Docket No. 1948-66.

48 T.C. 330 (1967)

JOHN I. APPLEBY AND CAROLYN M. APPLEBY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 16, 1967.


Attorney(s) appearing for the Case

Arthur W. Moore, for the petitioners.

Frank E. Wrenick, for the respondent.


MULRONEY, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1963 and 1964 in the respective amounts of $1,002.64 and $555.13.

The only assignment of error in the petition is that respondent erred in determining that their contributions to a trust did not qualify for the additional deduction provided in section 170(b)(1)(A), I.R.C. 1954.1

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