City Bank Farmers Trust Co. v. United States

HERLANDS, District Judge.

This motion to dismiss for lack of jurisdiction over the subject-matter is granted.

Plaintiff-trustee, having petitioned the Tax Court to review the Commissioner’s determination that the entire value of the trust was includible in the estate of the deceased settlor under sections 811(c) and 811(d) (2) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 811(c), (d) (2), is now barred from attempting to litigate the question of the inclusion of the trust in the settlor’s estate in the District Court, under section 911 of the Internal Revenue Code of 1939, 26 U.S.C.A. §…