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ALLEN v. COMMISSIONER

Docket Nos. 35455, 35456.

12 T.C.M. 1364 (1953)

Susan J. Allen v. Commissioner. Elizabeth R. Allen v. Commissioner.

United States Tax Court.

Entered December 4, 1953.

Attorney(s) appearing for the Case

Harry C. Stitt, Jr., Esq., and Edmund H. Senft, C. P. A., 118 East Market Street, York, Pa., for the petitioners. William G. Handfield, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined deficiencies in income tax of the petitioners for the year 1949 as follows:

  Docket No. 35455 Susan J. Allen.....  $551.93
  Docket No. 35456 Elizabeth R. Allen.   455.31

The issues for our decision are:

1. Whether the loss on the sale of certain stock in 1947 was sustained by the petitioners or the trust of which they were beneficiaries.

2. Whether the payment...

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