Sharp v. Commissioner of Internal Revenue

DICKINSON, District Judge.

There are two petitions for review of the decision of the Board of Appeals in the nature of cross-appeals. For clarity of treatment, we make them the subject of separate opinions. The questions raised concern the .estate of Walter P. Sharp, deceased, as taxpayer. The executors returned certain items of property as constituting the gross taxable estate of the decedent Upon this a tax of $9,855.58 was assessable. The Commissioner thought other items of property should be included calling for the assessment of a deficiency tax of $48,483.-88. The taxpayer asked for a…