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ESTATE OF BROWN v. C. I. R.

No. 28688 Summary Calendar.

425 F.2d 1406 (1970)

ESTATE OF Adelia E. BROWN, Deceased, G. C. Brown, Executor, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Fifth Circuit.

May 14, 1970.

Attorney(s) appearing for the Case

G. C. Brown, pro se, Hereford, Tex.

Frank Gaston, Plainview, Tex., for petitioner.

Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Atty., Tax Division, U. S. Dept. of Justice, Washington, D. C., K. Martin Worthy, Chief Counsel, Christopher J. Ray, Atty., Internal Revenue Service, Washington, D. C., Elmer J. Kelsey, Stephen Schwarz, Attys., Dept. of Justice, Tax Div., Washington, D. C., for respondent.

Before GEWIN, GOLDBERG and DYER, Circuit Judges.

PER CURIAM:

This is an appeal from a decision of the Tax Court finding a deficiency in estate tax due from decedent's estate in the amount of $22,157.02. This amount represents the additional tax due because of the difference between the reported value of 619 acres of farmland in Floyd County, Texas, at the date of decedent's death on May 13, 1962, of $136,595 (or an average of about $221.00 per acre) and the value found by the Tax Court of $208,000 (or $336.00 per...

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