BREIDERT v. COMMISSIONER

Docket No. 256-67.

50 T.C. 844 (1968)

GEORGE M. BREIDERT AND LORRAINE L. BREIDERT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 11, 1968.


Attorney(s) appearing for the Case

William Katz, for the petitioners.

Martin R. Simon, for the respondent.


The Commissioner determined a deficiency in petitioners' income tax for the year 1963 in the amount of $5,466.37, all of which is in dispute in these proceedings. The sole issue is whether petitioner George M. Breidert constructively received executor's fees of $9,100.20 in 1963.

FINDINGS OF FACT

Some of the facts have been stipulated, and, as stipulated, are incorporated herein by this reference along with accompanying exhibits.

George M. Breidert...

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