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ESTATE OF FEARON v. COMMISSIONER

Docket No. 19560.

16 T.C. 385 (1951)

ESTATE OF CHARLES FEARON, DECEASED, MARGARET H. FEARON, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 20, 1951.

Attorney(s) appearing for the Case

Stephen T. Dean, Esq., and Donald McDonald, Esq., for the petitioner.

W. Morgan Hunter, Esq., for the respondent.

Respondent has determined a deficiency in decedent's income tax for the period January 1 to April 12, 1943, in the amount of $5,017.34. The deficiency results from respondent's determination that the sum of $7,380 received by the decedent in 1942 from the Louisville Property Company (hereinafter referred to as Property Company) was taxable as an ordinary dividend rather than a distribution in complete liquidation as reported by the decedent.

FINDINGS OF FACT.

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