Aronson

Petitioner, Daniel Aronson, as guardian of Herbert Heilman Aronson and Marco Heilman Aronson, minors, seeks reversal of two decisions 1 2of the Board of Tax Appeals which determined that there were deficiencies aggregating $12,391.04 in respect of taxes on said minors’ income for the calendar year 1929. The deficiencies were held to have resulted from failure to report as income, and pay taxes on, gains derived from the exchange of 936 shares 2 of stock of Merchants National Trust & Savings Bank of Los Angeles for a like number of depositary certificates issued by Title Guarantee & Trust Company.

Facts concerning which no dispute exists are as follows:

Amy Heilman Aronson, mother of the above named minors, died intestate on February 9, 1920. The minors were her only heirs. Her brothers, Marco H. Heilman and Irving H. Heilman, were administrators of her estate. Her estate consisted, in part, of shares of stock of Heilman Commercial Trust & Savings Bank (hereafter called Heilman Bank) and of Merchants National Bank 3 of Los Angeles. On August 17, 1925, the administrators of her estate filed in the proper probate court their final account and petition for distribution. On October…