Estate of Theodore Geddings Tarver, Deceased, the Citizens and Southern National Bank of South Carolina v. Commissioner of Internal Revenue

SOPER, Circuit Judge.

This case comes before the court on a petition to review a decision of the Tax Court which upheld a determination by the Commissioner of Internal Revenue of a deficiency in federal estate tax in the sum of $55,011.40 against the Citizens and Southern National Bank of South Carolina as executor of the estate of Theodore Geddings Tarver, a resident of North Augusta, South Carolina. The testator died October 8, 1950. His will was probated and the bank was appointed as executor on October 13, 1950. Three questions are presented for decision.

1. Whether the notice of deficiency…