NORBURY SANATORIUM CO. v. COMMISSIONER

Docket No. 12957.

9 T.C. 586 (1947)

THE NORBURY SANATORIUM CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 6, 1947.


Attorney(s) appearing for the Case

Stanley Worth, Esq., for the petitioner.

A. H. Moorman, Esq., for the respondent.


Respondent determined a deficiency in petitioner's income tax for the year 1944 of $12,421.72, and a deficiency in declared value excess profits tax for the same year of $3,167.72. These deficiencies result from respondent's holding that petitioner realized taxable income in 1944 in an amount representing the value of the assets of a trust of which, respondent contends, petitioner became the owner in that year.

FINDINGS OF FACT.

Petitioner is an Illinois...

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