Estate of Ruth Hanna, Deceased, the National City Bank of Cleveland v. Commissioner of Internal Revenue

SHACKELFORD MILLER, Jr., Circuit Judge.

The petitioner, Estate of Ruth Hanna, deceased, sought in the Tax Court a re-determination of an income tax deficiency for the year 1958 in the amount of $11,-279.78. The Tax Court sustained the-deficiency assessment. Estate of Ruth Hanna, Deceased v. Commissioner, 37 T.C. 63. Petitioner seeks a review of the decision of the Tax Court.

The facts are stated in detail in the stipulation and in the opinion of the Tax Court, to which reference is made. For the purposes of this opinion, the following; basic facts are sufficient for a decision of the issue…