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ESTATE OF NARISCHKINE v. COMMISSIONER

Docket No. 20115.

14 T.C. 1128 (1950)

ESTATE OF SARAH L. NARISCHKINE, DECEASED, WILLIAM C. BREED AND CENTRAL HANOVER BANK AND TRUST COMPANY, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 12, 1950.

Attorney(s) appearing for the Case

George R. Sherriff, Esq., and George V. Mahoney, Esq., for the petitioners.

Michael Waris, Jr., Esq., for the respondent.

Respondent determined a deficiency in the amount of $26,660.54 in petitioners' income tax liability for the taxable year ended December 31, 1946.

The deficiency results from respondent's inclusion in petitioners' gross income for 1946 of the sum of $69,375 paid to petitioners, as the representatives of the decedent, Sarah L. Narischkine, in full settlement of alimony arrearages due the decedent.

FINDINGS OF FACT.

Petitioners are the executors of...

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