Estate of Parrott

Mary Emilie Parrott died March 1, 1922, a resident of the county of San Mateo, this state. The fair market value of her estate was appraised by the inheritance tax appraiser at $1,301,470.69.

The sole question presented by this appeal is whether the appraiser should have made a deduction of $260,000, as evidenced by a joint and several promissory note made by her and her co-maker, from the market value of said estate, instead of a deduction of but one-half of said amount, to wit, $130,000, which deduction was allowed by him as a debt owing by her at the time of her demise. The appeal was taken…