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UNITED STATES v. RUSSELL

No. 75-1388.

532 F.2d 175 (1976)

UNITED STATES of America, Appellee, v. Harriett C. RUSSELL, Executrix of the Estate of T. C. Russell, Deceased, Appellant.

United States Court of Appeals, Tenth Circuit.

Decided March 29, 1976.

Attorney(s) appearing for the Case

Daniel F. Ross, Atty., Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Jonathan S. Cohen, Attys., Tax Div., Dept. of Justice, Washington, D. C., E. Edward Johnson, U. S. Atty., and James A. Pusateri, Asst. U. S. Atty., Kansas City, Kan., on the brief), for appellee.

Joseph H. McDowell, Kansas City, Kan. (on the brief), for appellant.

Before SETH, BARRETT and DOYLE, Circuit Judges.

BARRETT, Circuit Judge.

This tax case is before us for the second time.1 The United States brought this suit in debt against Harriett Russell (Russell) as the surviving widow of T. C. Russell seeking payment of federal estate taxes of $116,165 which had been previously assessed against the estate of T. C. Russell.

Our prior opinion summarized the relevant facts:

At the date of his death, T. C. Russell and his wife, Harriett...

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