ESTATE OF FARRELL v. COMMISSIONER

Docket No. 19764.

12 T.C. 962 (1949)

ESTATE OF MARGARET RUTH BRADY FARRELL, DECEASED, NEILE F. TOWNER, CENTRAL HANOVER BANK AND TRUST COMPANY, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 8, 1949.


Attorney(s) appearing for the Case

Neile F. Towner, Esq., and Julian B. Erway, Esq., for the petitioners.

Clay C. Holmes, Esq., and Michael Waris, Jr., Esq., for the respondent.


These proceedings were brought for a redetermination of a deficiency in estate tax of $176,335.33. Petitioners claim an overpayment of $2,680.05. The primary litigated issue is whether respondent erred in disallowing as a deduction under Internal Revenue Code, section 812, a claim against the estate, representing a part of a note on which decedent was designated as maker.

The case was submitted upon a stipulation of facts and evidence adduced at the hearing. Those...

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