WILLITS v. COMMISSIONER

Docket No. 1715-66.

50 T.C. 602 (1968)

OLIVER G. WILLITS AND MARGARET F. WILLITS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 24, 1968.


Attorney(s) appearing for the Case

Joseph W. Price 3d, for the petitioners.

Max J. Hamburger and Peter J. Picotte II, for the respondent.


The Commissioner determined deficiencies in petitioners' income tax for 1960 and 1961 in the amounts of $156,917.26 and $80,523.33, respectively. The only adjustments in controversy are those relating to the Commissioner's determination that petitioner Oliver G. Willits actually or constructively received certain trustee's commissions in the amounts of $178,887.88 in 1960 and $131,107.95 in 1961.

FINDINGS OF FACT

The stipulation of facts, along with accompanying...

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