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ESTATE OF HOLLOWAY v. COMMISSIONER

Docket No. 11427.

10 T.C. 828 (1948)

ESTATE OF H. M. HOLLOWAY, DECEASED, HARVEY S. HOLLOWAY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 13, 1948.

Attorney(s) appearing for the Case

A. Calder Mackey, Esq., and Adam Y. Bennion, Esq., for the petitioner.

E. A. Tonjes, Esq., for the respondent.

This proceeding involves a Federal gift tax deficiency in the amount of $6,421.41 for the year 1944. The only issue is whether any portion of the property transferred to the donees was received as compensation for personal services actually rendered by H. M. Holloway's wife, Mary L. Holloway.

In accordance with a motion announcing the death on or about October 4, 1947, of H. M. Holloway (hereinafter referred to as decedent...

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