Newell v. Commissioner of Internal Revenue

EVANS, Circuit Judge.

The instant appeal involves the correctness of the assessment of a $20,259.52 deficiency in the estate tax of Charles C. Ingalls, deceased. Petitioners’ attack is directed to a single issue, one of fact, to-wit, the value of decedent’s 3,281 shares of common stock of the Ingalls Stone Company.

The facts: Decedent died October 24, 1928, owning 2,258 shares of the preferred stock and 3,281 shares of the common stock of the Ingalls Stone Company. The balance of that company’s stock, constituting only a minority interest, was owned by relatives and employees of the…