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ESTATE OF RUNNELS v. COMMISSIONER

Docket Nos. 5939-67, 5940-67.

54 T.C. 762 (1970)

ESTATE OF WILLIAM F. RUNNELS, DECEASED, LOU ELLA RUNNELS, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LOU ELLA RUNNELS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 13, 1970.

Attorney(s) appearing for the Case

Williard A. Herbert, for the petitioners.

John W. Dierker, for the respondent.

OPINION

FEATHERSTON, Judge:

In these consolidated cases respondent determined deficiencies for 1964 in the income tax of the Estate of William F. Runnels, deceased, Lou Ella Runnels, executrix, in the amount of $11,206.18, and Lou Ella Runnels in the amount of $9,655.57.

The issues for decision are:

(1) Whether cancellation of petitioners' indebtedness to Runnels Chevrolet Co. in consideration...

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