Estate of Migiel John Uline, Deceased v. District of Columbia

DANAHER, Circuit Judge:

The petitioners filed a District of Columbia income tax return in behalf of the Estate of Migiel John Uline for the year ending December 31, 1960, reporting the receipt of 1960 “dividend” income in the amount of $32,764.47. The Estate paid a tax of $1,031.06. The District tax authorities assessed a deficiency of $588,-355.82 with a resulting deficiency in tax of $31,805.03, plus interest. The District of Columbia Tax Court on September 30, 1963 upheld the District, and these review proceedings followed. The facts are not in dispute.

Until the death of the decedent Uline…