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SAMMONS v. COMMISSIONER

Docket No. 3964-67.

30 T.C.M. 626 (1971)

T.C. Memo. 1971-145

Charles A. Sammons, Individually and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent Executor v. Commissioner.

United States Tax Court.

Filed June 17, 1971.

Attorney(s) appearing for the Case

B. Thomas McElroy and David P. Smith, for the petitioners. Roy E. Graham, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined a deficiency of $965,258.96 in petitioners' income tax for the calendar year 1961. The only issue presented is whether petitioner Charles A. Sammons and his now deceased wife, Rosine Sammons, received dividend income during 1961 in the amount of $1,108,121.20.

Findings of Fact

Some of the facts have been stipulated. The stipulation of facts, together with the exhibits...

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