SILAGYE v. COMMISSIONER OF INTERNAL REVENUE

No. 51, Docket 21986.

192 F.2d 886 (1951)

SILAGYE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided December 3, 1951.


Attorney(s) appearing for the Case

C. J. Batter and Charles M. Trammell, New York City, for petitioner.

Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, Robert N. Anderson and Fred E. Youngman, Sp. Assts. to Atty. Gen., Charles Oliphant, and Helen Goodner, Washington, D. C., for Commissioner of Internal Revenue.

Before AUGUSTUS N. HAND, CHASE and CLARK, Circuit Judges.


PER CURIAM.

The petitioner, Joseph Silagye, executor of the Estate of Marie Szilagye, appeals from an order of the Tax Court sustaining an assessment by the Commissioner of Internal Revenue of a deficiency in estate taxes and a penalty for late filing of the executor's return, and from an order denying a motion for a rehearing.

The question presented with respect to the deficiency is whether the sum of $113,788.71 should be included in the gross estate of...

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