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KONNER v. COMMISSIONER

Docket Nos. 80975, 80976.

35 T.C. 727 (1961)

JACOB KONNER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JOAN KONNER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 6, 1961.

Attorney(s) appearing for the Case

Benjamin Nadel, Esq., for the petitioners.

Chapman H. Belew, Jr., Esq., for the respondent.

OPINION.

RAUM, Judge:

The Commissioner determined a deficiency in gift tax for 1955 in the amount of $165, and an addition to tax under section 6651 of the Internal Revenue Code of 1954 in the amount of $8.25 for failure to file a timely gift tax return, against each petitioner. The facts have been stipulated.

The question for decision is whether income interests given by means of a trust for the benefit of beneficiaries of two trusts (already...

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