Humes v. United States

Mr. Justice Brandéis

delivered the opinion of the Court.

This action was brought in the Court of Claims by the executors of Dellora R. Gates to recover $120,508.50, a part of the estate tax alleged to have been illegally exacted under the Revenue Act of 1918, c. 18, § 403, 40 Stat. 1057, 1098. The basis of the claim is that a sum of $482,034, which was disallowed in ascertaining the net estate taxable, should have been deducted from the gross amount of $11,783,072.30 disposed of by Article Fifty-first of the will. The sum disallowed represents the alleged present value of certain contingent…