Bryant v. Commissioner of Internal Revenue

SOPER, Circuit Judge.

This petition for review relates to a decision of the Tax Court of the United States in which a deficiency of $4-59.40 in the income and victory tax for the year 1943-, and a deficiency of $12221.05 in the income tax for the year 1944 was adjudicated against the petitioner.

Edith Moorhead Bryant, the taxpayer, was one of the beneficiaries and the remainderman of a trust estate created by the will of S. E. Moorhead, her father, a resident of New Yorle who died in 1941. He bequeathed 2500 shares of stock of Liggett & Myers Tobacco Company to the Guardian Trust Company of New…