Rosalie M. Schubert v. Commissioner of Internal Revenue

BOREMAN, Circuit Judge.

This case is here on petition to review the decision of the Tax Court' of the United States which affirmed the determination by the Commissioner of Internal Revenue of deficiencies in federal income taxes of the Petitioner. The facts hereinafter stated were stipulated and accordingly found by the Tax Court. Petitioner will be referred to as taxpayer.

Taxpayer’s mother, Gazelle K. Millhiser, hereinafter sometimes referred to as testatrix or lessor, owned real estate in Richmond, Virginia, described as 409 East Broad Street, located about sixty-one feet from the…