ESTATE OF HARRISON v. COMMISSIONER

Docket No. 101982.

16 T.C. 727 (1951)

ESTATE OF ROBERT LEWIS HARRISON, DECEASED, ROBERT WOODWARD BARNWELL ELLIOTT AND WILLIAM BYRD, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 6, 1951.


Attorney(s) appearing for the Case

William Byrd, Esq., for the petitioners.

Walt Mandry, Esq., for the respondent.


This proceeding arises from respondent's determination that the decedent as a transferee was liable for a deficiency in income tax for the calendar year 1930 in the amount of $375.

The sole issue herein is whether the decedent's estate is liable as a transferee for the unpaid income tax of the Southern and Atlantic Telegraph Company for the year 1930 under the provisions of section 311 of the Revenue Act of 1928.

FINDINGS OF FACT.

The petitioners...

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