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ESTATE OF COLLINS v. COMMISSIONER

Docket No. 62264.

31 T.C. 238 (1958)

ESTATE OF M. A. COLLINS, DECEASED, LILA T. COLLINS, ADMINISTRATRIX, AND LILA T. COLLINS, INDIVIDUALLY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 30, 1958.

Attorney(s) appearing for the Case

Hugh R. Dowling, Esq., William R. Frazier, Esq., and James E. Miller, Esq., for the petitioners.

Hugh G. Isley, Jr., Esq., for the respondent.

Respondent determined deficiencies in Federal income tax against the original petitioners herein, M. A. Collins and Lila T. Collins (husband and wife), for the years 1950 and 1951 in the respective amounts of $11,106.62 and $18,591.93. The deficiency for the year 1951 is here at issue. It arose by reason of respondent's determinations that the profits from the sales of lots in two real estate subdivisions during that year were taxable as ordinary income, and that the cost...

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