PENNSYLVANIA CO. FOR INSURANCES, ETC. v. BROWN

No. 14882.

6 F.Supp. 582 (1933)

PENNSYLVANIA CO. FOR INSURANCES ON LIVES AND GRANTING ANNUITIES et al. v. BROWN, Late Acting Collector of Internal Revenue.

District Court, E. D. Pennsylvania.

July 12, 1933.


Attorney(s) appearing for the Case

Benjamin O. Frick, of Philadelphia, Pa., for plaintiffs.

P. E. Miller, of Washington, D. C., and Thomas J. Curtin, Asst. U. S. Atty., and Charles D. McAvoy, U. S. Atty., both of Philadelphia, Pa., for defendant.


KIRKPATRICK, District Judge.

In their return for inheritance tax, the executors of Theodore C. Birnbaum claimed the amount of $327,861.24 as a deduction from the gross estate, on the ground that this was the amount of a bequest to certain charities. The Commissioner of Internal Revenue disallowed the deduction and determined a deficiency in the tax which with interest was paid by the executors who brought this suit for its recovery. The case was tried to the court...

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