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TOWNER v. COMMISSIONER OF INTERNAL REVENUE

No. 206, Docket No. 21595.

182 F.2d 903 (1950)

TOWNER et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided June 5, 1950.

Attorney(s) appearing for the Case

Theodore Pearson, of New York City (Neile F. Towner, of Albany, N. Y., and Hewitt A. Conway, of New York City, on the brief), for petitioners.

Hilbert P. Zarky, Sp. Asst. to Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., and Ellis N. Slack, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before L. HAND, Chief Judge, and CHASE and CLARK, Circuit Judges.

CLARK, Circuit Judge.

Petitioners seek review of a decision of the Tax Court, 12 T.C. 962, upholding the Commissioner's determination of an estate tax deficiency to the extent of $159,447.63 against the estate of Margaret Ruth Brady Farrell, late of Albany, New York, of whose estate they are executors. In making their return they deducted from the gross estate, upon computation of the net estate for tax purposes, a portion of the indebtedness...

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