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ALBERT R. GALLATIN WELSH TRUST v. COMMISSIONER

Docket No. 24997.

16 T.C. 1398 (1951)

TRUST UNDER DEED OF ALBERT R. GALLATIN WELSH DATED MARCH 19, 1935, GIRARD TRUST COMPANY, AS TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 20, 1951.

Attorney(s) appearing for the Case

George Craven, Esq., for the petitioner.

John A. Newton, Esq., for the respondent.

OPINION.

TIETJENS, Judge:

Respondent, under section 143 (b) of the Internal Revenue Code, determined a deficiency of $5,400 in the income tax liability of petitioner for withholding of tax at source on payments made to a nonresident alien individual in the year 1948. Petitioner appeals from this determination.

All the facts have been stipulated and are so found.

Albert R. Gallatin Welsh and Gabrielle B. Welsh were married on October...

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