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DAVENPORT v. COMMISSIONER

Docket No. 8394.

6 T.C. 62 (1946)

MALCOLM CLIFTON DAVENPORT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 11, 1946.

Attorney(s) appearing for the Case

Alfred F. Burgess, Esq., for the petitioner.

Edward L. Potter, Esq., for the respondent.

This proceeding involves a deficiency in income tax for the calendar year 1941 in the amount of $16,787.02, plus a 10 percent delinquency penalty in the amount of $1,678.70.

The main issue is whether the basis of certain property received by petitioner by "bequest, devise, or inheritance" was its value at the date of his decedent's death in 1918 or its value on date of distribution to him in 1928. A second issue raises the question...

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