
    Appeal of KATHRYN M. HASKELL, Executrix of the Estate of GEORGE S. HASKELL, Deceased.
    Docket No. 4335.
    Submitted October 7, 1925.
    Decided November 11, 1925.
    
      Robert L. Floyd, Esq., for the taxpayer.
    
      M. N. Fisher, Esq., for the Commissioner.
    Before James, Littleton, Smith, and Thus sell.
   . This is an appeal from the determination of a deficiency in income tax of George S. Haskell, deceased, for the calendar year 1921 in the amount of $236.27, arising from the holding of the Commissioner that a profit of $2,652.83 upon the sale of certain real estate was income to George S. Haskell during his lifetime. The executrix alleged in her petition that the said profit of $2,652.83 belonged to her.

FINDINGS OE FACT.

During the calendar year 1921 George S. Haskell, now deceased, was a resident of Chicago, Ill., engaged in business as a partner with one Isadore A. Grossman. In January, 1913, Kathryn M. Haskell, wife of George S. Haskell, and Isadore A. Grossman each contributed $1,500 for the purchase of certain real estate in the City of Chicago at a cost of $6,000; $3,000 being paid in cash and a mortgage given for $3,000. The title to the property was taken in the name of Kathryn M. Haskell. In December, 1921, this property was sold by Kathryn M. Haskell for $11,305.65, resulting in a total profit of $5,305.65. One-half of this profit belonged to Isadore A. Grossman and one-half, or $2,652.83, belonged to Kathryn M. Haskell.

DECISION.

The deficiency determined by the Commissioner is disallowed.  