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COMMERCIAL NAT. BANK OF CHARLOTTE v. UNITED STATES

No. 6394.

196 F.2d 182 (1952)

COMMERCIAL NAT. BANK OF CHARLOTTE v. UNITED STATES.

United States Court of Appeals Fourth Circuit.

Decided April 26, 1952.

Attorney(s) appearing for the Case

John S. Cansler, Charlotte, N. C. (Cansler & Cansler, Charlotte, N. C., on brief), for appellant.

Melva M. Graney, Sp. Asst. to Atty. Gen. (Ellis N. Slack, Acting Asst. Atty. Gen., Lee A. Jackson, Sp. Asst. to Atty. Gen., Thomas A. Uzzell, Jr., U. S. Atty., Asheville, N. C., and Francis H. Fairley, Asst. U. S. Atty., Charlotte, N. C., on brief), for appellee.

Before SOPER and DOBIE, Circuit Judges, and HUTCHESON, District Judge.

SOPER, Circuit Judge.

This suit relates to the deductibility of attorneys' fees as an administrative expense in computing the net estate of E. L. Baxter Davidson for estate tax purposes under Section 812(b) (2) of the Internal Revenue Code, 26 U.S.C.A. § 812(b) (2). Fees were paid for services rendered by attorneys in connection with a caveat of the will of the deceased under which an estate of approximately $800,000, consisting in great part of real estate in...

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