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ESTATE OF WADEWITZ v. COMMISSIONER

Docket No. 61526.

32 T.C. 538 (1959)

ESTATE OF EDWARD H. WADEWITZ, DECEASED, ROBERT S. CALLENDER, WYNNEFRED W. CALLENDER, CAMILLE W. WADEWITZ AND FIRST NATIONAL BANK AND TRUST COMPANY OF RACINE, EXECUTORS, AND NETTIE M. WADEWITZ, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 29, 1959.

Attorney(s) appearing for the Case

Leo C. Duersten, Esq., for the petitioners.

Thomas J. Donnelly, Jr., Esq., for the respondent.

OPINION.

PIERCE, Judge:

The respondent determined deficiencies in the income taxes of Edward and Nettie Wadewitz for the years 1949, 1950, and 1951, in the respective amounts of $8,861.80, $9,959.93, and $9,940.89.

The issues presented for decision are:

(1) Whether the income of the E. H. Wadewitz Trust #1 for the calendar years 1949, 1950, and 1951 was held or accumulated for future distribution to petitioner Nettie Wadewitz (one...

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