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ESTATE OF WEINERT v. COMMISSIONER

Docket No. 56328.

31 T.C. 918 (1959)

ESTATE OF H. H. WEINERT, DECEASED, JANE W. BLUMBERG, EXECUTRIX, AND HILDA B. WEINERT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 30, 1959.

Attorney(s) appearing for the Case

Leon O. Lewis, Jr., Esq., and Edgar Engelke, Esq., for the petitioners.

Harold A. Chamberlain, Esq., and Robert L. Liken, Esq., for the respondent.

OPINION.

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income tax of $817.31 and $4,193.86, for the calendar years 1949 and 1950, respectively. In their petition, petitioners seek a determination that there have been overassessments of $1,399.06 and $7,987.30 for the years 1949 and 1950, although the basis for the claimed overassessments is not clear.

The sole issue raised by the pleadings is whether petitioners were taxable...

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