United States v. Price

RULING AND ORDER

STUART, Chief Judge.

This action was initiated by the United States to recover from the executors of the Estate of Marie Price Reel the full amount of an assessment for unpaid estate taxes. The executors tendered “flower bonds” 1 which, if accepted at par value as required by the terms, would have satisfied the tax obligation. The United States refused to accept the bonds claiming the conditions for acceptance at par were not met because the decedent did not own the bonds at her death. The claim of non-ownership is based upon the fact that the bonds were purchased by her agent…