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CHICK v. COMMISSIONER OF INTERNAL REVENUE

No. 4251.

166 F.2d 337 (1948)

CHICK et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

February 27, 1948.

Attorney(s) appearing for the Case

Robert A. B. Cook, of Boston, Mass. (Phipps, Durgin & Cook, of Boston, Mass., on the brief), for petitioners.

Helen Goodner, Sp. Asst. to the Atty. Gen. (Theron L. Caudle, Asst. Atty. Gen., Helen R. Carloss and Robert M. Weston, Sp. Assts. to the Atty. Gen., on the brief), for Commissioner of Internal Revenue.

Before MAGRUDER, MAHONEY and WOODBURY, Circuit Judges.

WOODBURY, Circuit Judge.

This consolidated petition for review of two decision of the Tax Court of the United States presents a single question. It is whether throughout the calendar year 1940 the estate of the petitioners' father, Isaac W. Chick, was in the process of "administration or settlement" within the meaning of § 161(a) (3)1 of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 161(a) (3), and the Regulations promulgated...

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