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ESTATE OF HENRY WILSON v. COMMISSIONER

Docket Nos. 92262, 92263, 92264.

2 T.C. 1059 (1943)

ESTATE OF HENRY WILSON, FRANCIS A. WILSON, BENEFICIARY, TRANSFEREE AND CONSTRUCTIVE EXECUTOR; MARY H. WILSON, BENEFICIARY, TRANSFEREE AND CONSTRUCTIVE EXECUTRIX; AND WINIFRED T. WILSON, BENEFICIARY, TRANSFEREE AND CONSTRUCTIVE EXECUTOR, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 30, 1943.

Attorney(s) appearing for the Case

Louis Janin, Esq., for the petitioners.

Alva C. Baird, Esq., for the respondent.

These consolidated proceedings involve an estate tax deficiency and penalties on the transfer of the net estate of Henry Wilson, deceased. The respondent determined a deficiency of $169,580.66, a 25 percent penalty of $42,395.17 for failure to file a return, and a 50 percent penalty of $84,790.33 for evasion of tax in filing a fraudulent claim for refund of Federal estate tax, or a total of $296,766.16. A deficiency and penalties were determined separately against each petitioner...

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