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ESTATE OF COLLINO v. COMMISSIONER

Docket No. 46913.

25 T.C. 1026 (1956)

ESTATE OF MICHAEL COLLINO, DECEASED, MORTIMER J. GOODSTEIN, ADMINISTRATOR D. B. N., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 10, 1956.

Attorney(s) appearing for the Case

Mortimer J. Goodstein, Esq., for the petitioner.

S. Jarvin Levison, Esq., and Emil Sebetic, Esq., for the respondent.

The Commissioner determined a deficiency in estate tax in the amount of $31,484.09. In addition, he imposed a 25 per cent addition to the tax, in the amount of $7,871.02, under the provisions of section 3612 (d) (1) of the 1939 Code because the estate tax return was not filed within the time prescribed by law.

The Commissioner now concedes that two classes of property are not includible in the gross estate of the decedent...

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