First National Bank v. Allen

DAVIS, Chief Judge.

Plaintiff herein qualified as executor of the will of Conkey P. Whitehead and on January 31, 1942, within the time fixed by law, filed a federal estate tax return, disclosing a tax due of $904,654.82, which amount was paid with the return. On *134January 20, 1945, the Commissioner of Internal Revenue gave notice to the taxpayer of an alleged deficiency of estate taxes in the principal amount of $2,109,-675.04, which taxpayer paid on April 2, 1945, together with interest in the amount of $400,202.70. On July 19, 1945, an additional payment of interest .in the amount of $635.56…