Opinion
No. 88, Docket 21764.
Argued January 3, 1951.
Decided January 19, 1951.
On petition to review an order of the Tax Court in banc assessing a deficiency in estate taxes for the year, 1945.
Shearman Sterling Wright and Paul R. Russell, all of New York City (Charles M. Baudinet, New York City, of counsel), for petitioner.
Charles Oliphant, Theron L. Caudle, Washington, D.C., George D. Webster, Washington, D.C., Ellis N. Slack, Sp. Asst. to Atty. Gen., for respondent.
Before L. HAND, Chief Judge, and SWAN and AUGUSTUS N. HAND, Circuit Judges.
Order reversed and cause remanded for a redetermination of the amount of the tax liability on the authority of Jandorf's Estate v. Commissioner of Internal Revenue, 2 Cir., 171 F.2d 464 and Pennsylvania Company for Banking and Trusts v. United States, 3 Cir., 185 F.2d 125.