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ESTATE OF COID HURLBURT v. COMMISSIONER

Docket No. 51779.

25 T.C. 1286 (1956)

ESTATE OF COID HURLBURT, DECEASED, AND MERLE HURLBURT, SURVIVING WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 21, 1956.

Attorney(s) appearing for the Case

Arnold M. Chutkow, Esq., for the petitioners.

William H. Welch, Esq., for the respondent.

OPINION.

MULRONEY, Judge:

The Commissioner determined a deficiency in income tax in the amount of $4,555.07 for the calendar year 1947. The sole issue is whether certain contracts entered into by Coid Hurlburt, decedent, in the sale of certain parcels of real estate in 1947 were includible in income as amounts realized under section 111 (b) of the 1939 Internal Revenue Code.

All of the facts have been stipulated and they are herein incorporated...

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