Commissioner of Internal Revenue v. The Leon A. Beeghly Fund, the Union National Bank of Youngstown, Ohio, Trustee

SHACKELFORD MILLER, Jr., Chief Judge.

This proceeding involves the federal income tax liability for the year 1949 of The Leon A. Beeghly Fund, a trust, hereinafter referred to as “taxpayer,” “Beeghly Fund,” or “Fund,” with respect to which the Commissioner determined a deficiency in such tax in the sum of $10,280,673.27. The case involves tax exemption of the Beeghly Fund under Section 101(6) of the Internal Revenue Code of 1939, claimed by the taxpayer, and also deductions from gross income claimed by the taxpayer under Section 162(a), Internal Revenue Code. On review by the Tax Court it was…