United States v. Erb

AUGUSTUS N. HAND, Circuit Judge.

On March 14, 1925, the Commissioner . of Internal Revenue assessed additional income taxes amounting to $139,750.-66 against Elmer E. Smathers, of whose will the defendants became executors. Smathers thereafter filed a claim for the reconsideration of the assessment and the abatement of the tax, and as security for payment of such amount as, on reconsideration, might be found due, together with penalties, gave his personal bond for $150,000. On February 5, 1927, the claim for abatement was allowed to the extent of $10,952.27, but was otherwise rejected so that…