William S. Hall and American Fletcher National Bank and Trust Company, Co-Executors of the Will of Helen S. Hall, Deceased v. United States

MAJOR, Circuit Judge.

Plaintiffs are the Executors of the Will of Helen S. Hall, who died February 18, 1960. A Federal Estate Tax Return was duly filed, showing a tax in the amount of $611.88, which was paid on or about May 18, 1961. Subsequently, the Commissioner of Internal Revenue determined and assessed a net deficiency in the amount of $48,708.96, together with interest in the amount of $3,920.74, which amounts were paid on or about September 28, 1962. The deficiency determined by the Commissioner resulted from inclusion in the decedent’s taxable estate the value of a trust created by her…