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ESTATE OF SIDLES v. COMMISSIONER

Docket No. 6563-73.

65 T.C. 873 (1976)

ESTATE OF HARRY B. SIDLES, DECEASED, DANIEL J. MONEN, JR., AND JANICE P. SIDLES, CO-EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 29, 1976.

Attorney(s) appearing for the Case

William E. Seidler and John J. Gross, for the petitioners.

Ronald M. Frykberg, for the respondent.

OPINION

DAWSON, Chief Judge:

Respondent determined deficiencies of $160,203 and $2,197 in petitioners' Federal income taxes for the taxable years ended May 31, 1969, and May 31, 1970, respectively.

Some issues have been conceded by petitioners. The primary issue for our decision is whether a liquidating distribution received by the Estate of Harry B. Sidles from Bi-State Distributing Corp. constituted "income in respect of a decedent" within...

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