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ESTATE OF HUESMAN v. COMMISSIONER

Docket No. 20164.

16 T.C. 656 (1951)

ESTATE OF RALPH R. HUESMAN, DECEASED, NURMA W. HUESMAN, FRED B. HUESMAN, AND THE FARMERS AND MERCHANTS NATIONAL BANK OF LOS ANGELES, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 29, 1951.

Attorney(s) appearing for the Case

H. B. Thompson, Esq., for the petitioners.

Robert H. Kinderman, Esq., for the respondent.

OPINION.

RICE, Judge:

The Commissioner determined a deficiency in income tax for the fiscal year ended April 30, 1945, in the amount of $57,923.50. The sole issue is whether in determining taxable net income of the estate, petitioners were correct in deducting an amount of $80,517 under section 162 of the Internal Revenue Code.

All of the facts were stipulated, are so found and are incorporated herein.

The return was filed with the...

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