Respondent has determined a deficiency in income tax for the year 1941 in the amount of $12,194.86. He has determined that the estate of Robert C. Alston was not under administration in 1941 and that the income of the estate is taxable to petitioner, the sole beneficiary. The question is whether the estate was in process of administration so as to have been a taxable entity in 1941 within the meaning of section 161 (a) (3) of the Internal Revenue Code.
Petitioner...
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