Minnie Viles, Administratrix of the Estate of Cloyd H. Viles, Deceased Harvey Viles Inez Viles Whaley Minnie Viles v. Commissioner of Internal Revenue

MILLER, Circuit Judge.

The petitioners seek a review of the judgment of the Tax Court sustaining the assessment of income taxes made by the Commissioner against them for the years 1947, 1948 and 1949.

The taxpayer Cloyd H. Viles filed individual income tax returns for 1947 and 1948. No return was filed by or for him for 1949. He died January 8, 1950. His mother, Minnie Viles, was appointed successor administratrix of his estate on April 4, 1950. In the distribution of the estate she distributed to the taxpayer’s brother, Harvey Viles, and to the taxpayer’s sister, Inez Viles Whaley, the sum of…