B. Altman & Co. v. United States

BOOTH, Chief Justice.

Benjamin Altman devised to the plaintiff corporation real property located in the city' of New York, having at the time it was received an agreed value of $5,381,500. The plaintiff corporation in its income tax return for the calendar year 1913, the year in which it received the above devise, did not report the value of the same as taxable income. On January 5, 1923, the Commissioner of Internal Revenue assessed an additional income tax predicated upon the inclusion of the value of the devise received by the corporation from Benjamin Altman as aforesaid.

On July 2, 1923,…