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HIECKE TRUST v. COMMISSIONER

Docket No. 6214.

6 T.C. 30 (1946)

EDWARD M. AND FRED E. HIECKE TRUST, UNDER WILL OF JENNIE M. WAINWRIGHT, ERNEST L. MILLER AND CITY NATIONAL BANK OF CLINTON, TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 10, 1946.

Attorney(s) appearing for the Case

Harry Thom, Esq., and Joseph W. North, C. P. A., for the petitioners.

Gene W. Reardon, Esq., for the respondent.

The Commissioner determined deficiencies of $14,443.40 and $17,616.28 for the calendar years 1940 and 1941 in the income tax of a single trust. The only issue for decision is whether the tax should be computed for a single trust or upon the basis of a separate trust for each of the two beneficiaries.

FINDINGS OF FACT.

Jennie M. Wainwright died testate on April 30, 1939, while residing in Clinton, Iowa. Her will provided...

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