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COMMISSIONER OF INTERNAL REVENUE v. CRAWFORD'S ESTATE

No. 8196.

139 F.2d 616 (1943)

COMMISSIONER OF INTERNAL REVENUE v. CRAWFORD'S ESTATE et al.

Circuit Court of Appeals, Third Circuit.

Decided December 20, 1943.

Attorney(s) appearing for the Case

Muriel S. Paul, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

John G. Buchanan, of Pittsburgh, Pa. (David B. Buerger and Smith, Buchanan & Ingersoll, all of Pittsburgh, Pa., on the brief) for respondent.

Before BIGGS, MARIS, and GOODRICH, Circuit Judges.

BIGGS, Circuit Judge.

In this case the executors of Crawford's estate claim that they are entitled to deduct as income paid certain payments made to a trust estate created under Crawford's will. The pertinent statutory provisions are those of Section 162(c) of the Revenue Act of 1936.1

The facts have been stipulated. The testator was a resident of Pennsylvania. His will appointed the Union...

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