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WOODHALL v. C. I. R.

No. 26833.

454 F.2d 226 (1972)

Chrissie H. WOODHALL, a widow, Estate of W. Lyle Woodhall, Deceased, Chrissie H. Woodhall, Executrix, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

January 7, 1972.

Attorney(s) appearing for the Case

George Constable (argued), Seattle, Wash., for petitioners-appellants.

Janet Spragens (argued), Atty., Tax Div., Dept. of Justice, Washington, D. C., Johnnie M. Walters, Asst. Atty. Gen., K. Martin Worthy, Chief Counsel, Meyer Rothwacks, Grant W. Wiprud, John S. Brown, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before DUNIWAY and CHOY, Circuit Judges, and GOODWIN, District Judge.

CHOY, Circuit Judge:

W. Lyle Woodhall died on January 20, 1964, leaving Mrs. Woodhall as his sole heir and executrix. For 1964, Mrs. Woodhall filed a joint income tax return as surviving spouse. She also filed a fiduciary income tax return for the estate for part of 1964. For 1965, she filed an individual tax return and a fiduciary return.

The Commissioner of Internal Revenue determined deficiencies against Mrs. Woodhall for the years 1964 and 1965. The ground...

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