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EQUITABLE LIFE ASSURANCE SOCIETY v. COMMISSIONER

Docket No. 31470.

19 T.C. 264 (1952)

THE EQUITABLE LIFE ASSURANCE SOCIETY OF THE UNITED STATES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 19, 1952.

Attorney(s) appearing for the Case

Stuart McCarthy, Esq., for the petitioner.

Francis J. Butler, Esq., for the respondent.

The respondent determined that the petitioner was liable for estate tax of the estate of Avis A. Roudabush in the amount of $5,240.72 as a transferee and trustee of the property of this estate.

Two issues were raised by the pleadings. One of these concerned the running of the statutory period of time within which any part of the deficiency could be assessed against the transferee. Petitioner has made no argument with respect...

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