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WEILLER v. COMMISSIONER OF INTERNAL REVENUE

No. 4.

64 F.2d 480 (1933)

WEILLER et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

April 17, 1933.

Attorney(s) appearing for the Case

Wilbur C. Davidson, of New York City, for petitioners.

G. A. Youngquist, Asst. Atty. Gen., Sewall Key and Francis H. Horan, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Lewis S. Pendleton, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before MANTON, AUGUSTUS N. HAND, and CHASE, Circuit Judges.

AUGUSTUS N. HAND, Circuit Judge.

Louis Heilbroner died June 26, 1924, leaving a will of which the petitioners became executors. On June 24, 1925, they filed their return for the federal estate tax. On July 3, 1926, the Commissioner of Internal Revenue sent to these executors a "deficiency notice" fixing a deficiency in their tax at $20,178.84. This deficiency was based upon the failure of the executors to include in their tax return certain life insurance policies...

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