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HAMMOND v. COMMISSIONER

Docket No. 45705.

13 T.C.M. 903 (1954)

T. C. Memo. 1954-162

Estate of Harry W. Hammond, Deceased, Citizens National Trust and Savings Bank of Riverside, Trustee of the Harry W. Hammond Trust v. Commissioner.

United States Tax Court.

Filed September 29, 1954.

Attorney(s) appearing for the Case

Walter L. Nossaman, Esq., 900 Wilshire Boulevard, Los Angeles, Calif., Joseph D. Brady Esq., and James L. Wood, Esq., for the petitioner. Donald P. Chehock, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The respondent determined a deficiency of $136,979.94 in the estate tax of the estate of Harry W. Hammond, deceased. Issues presented by the pleadings are the correctness of the respondent's action (1) in failing to comply with the mandate of section 824, Internal Revenue Code of 1939, when he determined in 1950 that the fair market value of 662¼...

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