Ray Oil Co. v. Commissioner

*1208OPINION.

Matthews:

1. The first proceeding, Docket No. 34332, arises on a deficiency of $1,105.94 in income tax for the calendar year 1923 and involves the sole question, whether the petitioner was taxable in that year as a trust or as an association under section 2 (2) of the Revenue Act of 1921. The petitioner invoked the aid of section 704 (a) of the Bevenue Act of 1928, set out in the margin.1 The rulings of the Commissioner referred to in this section are those cited in E. A. Landreth, 15 B.T.A. 655; Wilkins & Lange, 15 B.T.A. 1183; Woodrow Lee Trust, 17 B.T.A. 109; and Van Cleave Trust,…