ESTATE OF HURD v. COMMISSIONER

Docket No. 11556.

9 T.C. 681 (1947)

ESTATE OF GEORGE F. HURD, PATRICIA KENDALL HURD, EXECUTRIX, JOHN HURD AND WILLIAM B. HURD, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 15, 1947.


Attorney(s) appearing for the Case

Albert E. James, Esq., and Hugh Satterlee, Esq., for the petitioners.

Ellyne E. Strickland, Esq., for the respondent.


The Commissioner determined a deficiency of $51,444.86 in estate tax. The issues for decision are: (1) Whether the period of limitations for assessment and collection expired without the proper mailing of a notice of deficiency; (2) whether the proceeds of nine policies of insurance on the life of the decedent received by his former wife were properly included in his gross estate under section 811 (c), or, in the alternative, whether a deduction of a like amount should have...

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