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ESTATE OF SENIOR v. COMMISSIONER

Docket No. 31443.

12 T.C.M. 90 (1953)

Estate of Harold B. Senior, Deceased, Eleanor S. Senior, Administratix d. b. n. v. Commissioner.

United States Tax Court.

Entered February 9, 1953.

Attorney(s) appearing for the Case

Lorin W. Willis, Esq., and Leonard McMahon, Esq., for the petitioner. Joseph Landis, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in income tax of H. B. Senior for the calendar year 1946 in the amount of $8,167.44. The issues as presented for decision are whether Senior was entitled to deduct as compensation of employees the value of shares of stock which he distributed in 1946 and what was the fair market value of those shares.

Findings of Fact

Harold B. Senior died on December 5, 1948. His...

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