REPUBLIC NATIONAL BANK OF DALLAS v. C. I. R.

No. 20277.

334 F.2d 348 (1964)

REPUBLIC NATIONAL BANK OF DALLAS, Trustee, Transferee, Estate of R. B. George, Deceased, Transferor, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

July 16, 1964.


Attorney(s) appearing for the Case

L. E. Elliott, Dallas, Tex., for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Crane C. Hauser, Chief Counsel, Charles Owen Johnson, Atty., I. R. S., Ralph Spritzer, Robert N. Anderson, Morton K. Rothschild, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before HUTCHESON, BROWN and GEWIN, Circuit Judges.


GEWIN, Circuit Judge.

This is a petition for review of a decision of the United States Tax Court in favor of the Commissioner of Internal Revenue and against the petitioner, who is the trustee and transferee of the estate of R. B. George, deceased (decedent).

Decedent died testate on March 2, 1956. His estate tax return was filed May 31, 1957, in which a gross estate of $4,246,228.51 was reported. The estate was in administration from March 2, 1956, to November...

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