ESTATE OF RICE v. COMMISSIONER

Docket No. 6570.

7 T.C. 223 (1946)

ESTATE OF GEORGE RICE, FAE H. RICE, HAROLD M. GREENEBAUM AND THE CHASE NATIONAL BANK OF THE CITY OF NEW YORK AS EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 26, 1946.


Attorney(s) appearing for the Case

John A. Gage, Esq., for the petitioner.

Ellyne E. Strickland, Esq., for the respondent.


The respondent determined a deficiency of $2,633.87 in the estate tax liability of the estate of George Rice, deceased. The petitioners claim an overassessment of $832.08, plus an additional credit of $2,778.11 for state taxes paid to the State of New York, or a total overassessment of $3,610.19.

The sole issue is the proper amount of deduction allowable for property previously taxed, under the provisions of section 812 (c), Internal Revenue Code, as amended by section...

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