Greenwood v. Commissioner of Internal Revenue

GARRECHT, Circuit Judge.

There is presented here a petition for review of a decision of the United States Board of Tax Appeals, 1 wherein it was decided that a deficiency existed in the federal estate tax returned by petitioner, Kenneth R. Greenwood, as administrator with-the-will-annexed of the esta'te of Charles H. Greenwood, deceased.

Petitioner, who is also the son of decedent, reported the property involved in this case as being community-owned, explaining that in the administration of the estate he was endeavoring to carry out the “ideas” of his father, who had always stated that he…