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SHAFFER v. COMMISSIONER

Docket No. 53993.

29 T.C. 187 (1957)

R. O. SHAFFER AND MILDRED M. SHAFFER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 7, 1957.

Attorney(s) appearing for the Case

Whitfield J. Collins, Esq., for the petitioners.

James F. Hoge, Jr., Esq., and James Q. Smith, Esq., for the respondent.

FISHER, Judge:

Respondent determined a deficiency of $4,362.56 in petitioners' income tax for the calendar year 1951. The deficiency is based upon respondent's determination that petitioners are not entitled to avail themselves of the provisions of section 107 (a), I. R. C. 1939, with respect to a portion of the amounts received by Ray O. Shaffer in 1951 as trustee of Texasteel Manufacturing Company, a debtor. The sole question for our decision is whether or...

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