NEMSER v. COMMISSIONER

Docket No. 481-74.

66 T.C. 780 (1976)

ALAN NEMSER AND SELMA W. NEMSER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 27, 1976.


Attorney(s) appearing for the Case

Alan Nemser, pro se.

Theodore M. David, for the respondent.


OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency of $6,782.32 in petitioners' 1968 Federal income tax. The parties have stipulated that the issue for decision is whether petitioner Alan Nemser is a beneficiary succeeding to the property of a trust within the meaning of section 642(h)(2)1 so as to entitle him to take as a deduction against his personal income his pro rata share of the unused deductions in...

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