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ESTATE OF RAINGER v. COMMISSIONER

Docket No. 8995.

12 T.C. 483 (1949)

ESTATE OF RALPH RAINGER, DECEASED, ELIZABETH RAINGER, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 30, 1949.

Attorney(s) appearing for the Case

Harry J. Miller, Esq., and George T. Altman, Esq., for the petitioner.

H. A. Melville, Esq., for the respondent.

Five issues were raised in connection with the determination of deficiency in estate tax in the amount of $35,804.96. Petitioner originally raised the issue of the constitutionality of the 1942 amendment to section 811 (e) (2) of the Internal Revenue Code. The proceedings were then placed upon the reserve calendar, pending decisions of the Supreme Court of the United States in Fernandez v. Wiener, 326 U.S. 340, and United States...

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