Axe v. United States

HILL, Chief Judge.

These are actions for the refund of income taxes, penalties and interest for the calendar years 1953 and 1954.

All of the material facts have been stipulated.

The controversy arises from the sale of certain real estate in the years 1953 and 1954.

The taxpayers, Ruth Axe (formerly Ruth Wilson) and Marlene Fitch, are mother and daughter.

Prior to September 4, 1953, Ruth Axe held a life estate in 240 acres of land and improvements under the will of her grandfather, T. O. Tanton. On September 4, 1953, the taxpayer, Axe, and her daughter, Marlene Fitch, who held a contingent…