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ESTATE OF CASWELL v. COMMISSIONER

Docket Nos. 27017, 27018.

17 T.C. 1190 (1952)

ESTATE OF WALLACE CASWELL, DECEASED, JENNIE J. CASWELL, ADMINISTRATRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ESTATE OF CHARLES HENRY CASWELL, DECEASED, EARL W. CASWELL, ADMINISTRATOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 18, 1952.

Attorney(s) appearing for the Case

Wareham C. Seaman, Esq., for the petitioners.

Charles W. Nyquist, Esq., for the respondent.

OPINION.

TURNER, Judge:

The proceeding at Docket No. 27017, the Estate of Wallace Caswell, involves a deficiency in income tax for 1945 of $7,828.97, and that at Docket No. 27018, the Estate of Charles Henry Caswell, a deficiency for the same year, of $5,278.10.

The primary issue presented is whether income was realized by the taxpayers in 1945 upon the receipt of certificates issued by a cooperative...

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