Estate of Para Pierce Aldrich, Deceased, City National Bank of Baton Rouge, Louisiana v. Commissioner of Internal Revenue

INGRAHAM, Circuit Judge:

The executor of the estate of Para Pierce Aldrich appeals the decision of the Tax Court that the Commissioner correctly determined a deficiency in the decedent’s estate tax in the amount of $227,231.69. The case was submitted to the Tax Court on stipulations and briefs at the request of the parties. In view of the fact that counsel did not wish to orally argue the case in that court, we carefully examined the record and briefs to determine whether oral argument would be helpful to us in resolving the issues presented on this appeal. Concluding that it would not, we…