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COMMISSIONER OF INTERNAL REVENUE v. RIVERA'S ESTATE

No. 202, Docket 22896.

214 F.2d 60 (1954)

COMMISSIONER OF INTERNAL REVENUE v. RIVERA'S ESTATE et al.

United States Court of Appeals Second Circuit.

Decided June 10, 1954.

Attorney(s) appearing for the Case

H. Brian Holland, Ellis N. Slack, Lee A. Jackson and I. Henry Kutz, Washington, D. C., for petitioner.

Claude A. Hope and Eugene Blanc, Jr., New York City, for respondent; Guillermo E. Gonzalez and Jorge L. Cordova, San Juan, Puerto Rico, of counsel.

Before CLARK, FRANK and MEDINA, Circuit Judges.

MEDINA, Circuit Judge.

This appeal involves a federal estate tax assessed against the estate of Clotilde Santiago Rivera, deceased, and is taken from the decision of the Tax Court entered on March 2, 1953, determining that there is an overpayment in estate tax in the amount of $69,327.87, which was paid after the mailing of the notice of deficiency. The question presented on this appeal is whether or not Congress exempted from the federal estate tax assets situated...

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