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ESTATE OF WHITLOCK v. COMMISSIONER

Docket No. 386-70.

59 T.C. 490 (1972)

ESTATE OF LEONARD E. WHITLOCK, DECEASED, GEORGIA M. WHITLOCK, EXECUTRIX, AND GEORGIA M. WHITLOCK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 29, 1972.

Attorney(s) appearing for the Case

R. Eugene McGannon and Philip J. Erbacher, for the petitioners.

Edward G. Lavery, for the respondent.

OPINION

FORRESTER, Judge:

Respondent determined deficiencies in petitioners' income tax of $25,106.64, $1,552.76, $17,328.88, and $141,985.23 for the taxable years 1963, 1964, 1965, and 1967, respectively. The main issue we must decide is whether petitioners, who, for the taxable years 1964, 1965, and 1967, were U.S. shareholders subject to tax under section 551(b)1 on income of a controlled foreign corporation, were required...

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