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SWANSON v. COMMISSIONER

Docket Nos. 469-72 — 471-72.

33 T.C.M. 296 (1974)

T.C. Memo. 1974-61

W. Clarke Swanson, Jr., 1950 Trust under Instrument Dated January 3, 1955, Swanco Trust Company, Trustee v. Commissioner. Carol Swanson Rhoden, 1950 Trust under Instrument Dated January 3, 1955, Swanco Trust Company, Trustee v. Commissioner. Gerock Hurley Swanson, 1950 Trust under Instrument Dated January 3, 1955, Swanco Trust Company, Trustee v. Commissioner.

United States Tax Court.

Filed March 11, 1974.

Attorney(s) appearing for the Case

Donald R. Osborn, 48 Wall St., New York, N.Y., and William F. Indoe, for the petitioners. Robert J. Murray, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined deficiencies in petitioners' income taxes for the year ending December 31, 1961, as follows:

                                      Amount of
        Petitioner                    Deficiency

  Carol Swanson Rhoden Trust .......  $95,175.43
  Gerock Hurley Swanson Trust ......   97,593.60
  W. Clarke Swanson, Jr. Trust .....   95,126.02

The issue is whether...

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