Johnstone v. Commissioner of Internal Revenue

WILBUR, Circuit Judge.

Petitioner seeks a review of the order of the Board of Tax Appeals sustaining the determination of the Commissioner of Internal Revenue of a deficiency of $12,881.81 in the federal estate tax on the estate of Allerton Johnstone, deceased, of which petitioner is executrix.

The facts are not disputed and can be summarized as follows;

The petitioner is the executrix of Aller-ton Johnstone, deceased, letters testamentary having been duly issued to her on August 19, 1929, by the superior court of the state of California in and for the county of Los Angeles.

Allerton Johnstone,…