Lindley v. Commissioner of Internal Revenue

CHASE, Circuit Judge.

The petitioner is one of several heirs at law of Mary T. Hill, who died intestate in 1921. The administrator of the estate of Mary T. Hill filed an estate tax return and paid the tax computed thereon. Subsequently, the Commissioner determined a deficiency in tho tax amounting to $.1,130,616.08. The administrator paid the deficiency under protest and brought suit in the District Court for the District of Minnesota to recover that as well as the original tax paid. The suit was unsuccessful, and, upon advice of counsel, the administrator declined- to take an appeal.…