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ESTATE OF GORDON v. COMMISSIONER

Docket No. 27792.

17 T.C. 427 (1951)

THE ESTATE OF MARY G. GORDON, DECEASED, THE FIRST NATIONAL BANK OF MIDDLETOWN, OHIO, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 26, 1951.

Attorney(s) appearing for the Case

Timothy S. Hogan, Esq., and Fred J. Schatzmann, Esq., for the petitioner.

Lyman G. Friedman, Esq., for the respondent.

This case involves income tax for the calendar year 1946. Respondent determined a deficiency in the amount of $8,785.30. The petitioner claims that the decedent erroneously reported an amount of $25,000 as income and that there was an overpayment of $3,322.86. Respondent, with leave of the Court, amended his original answer to conform to the proof adduced at the trial and asserted a deficiency in the amount of $27,014.26. At the hearing petitioner conceded the correctness...

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