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CARTER v. COMMISSIONER

Docket Nos. 27918, 27919.

17 T.C. 994 (1951)

JEAN LAING CARTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. L. L. CARTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 13, 1951.

Attorney(s) appearing for the Case

Stanley Pedder, Esq., for the petitioners.

Robert G. Harless, Esq., for the respondent.

The respondent has determined deficiencies in the sum of $99.30 in the income tax of Jean Laing Carter for 1944 and 1945, and deficiencies of $1,207.91, $1,262.84, and $1,126.76 in the income tax of L. L. Carter for 1943, 1944, and 1945, respectively. Issues presented for determination are (1) whether certain amounts received during the years 1942 through 1945 by L. L. Carter from the Provident Fund Of The Combined Petroleum Companies constituted long term capital gain, ...

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