Farmers Loan & Trust Co. v. United States

The plaintiffs are the executors of the last will of George Arents, who died on February 22, 1918. During the year 1918 plaintiffs paid to the State of New York a transfer tax of $364,876.56 on the estate of the decedent. On March 15, 1919, they made an income-tax return for the estate for the year 1918, and failed to claim a deduction of the transfer tax referred to, and voluntarily and without protest made payment to the United States in 1919 of the taxes due on said return amounting to $78,770.90. Thereafter the commissioner assessed an additional tax of $249.16, which was paid by…