Commercial Nat. Bank of Charlotte v. United States

SOPER, Circuit Judge.

This suit relates to the deductibility of attorneys’ fees as an administrative expense in computing the net estate of E. L. Baxter Davidson for estate tax purposes under Section 812(b) (2) of the Internal Revenue Code, 26 U.S.C.A. § 812(b) (2). Fees were paid for services rendered by attorneys in connection with a caveat of the will of the deceased under which an estate of approximately $800,000, consisting in great part of real estate in the business section of Charlotte, North Carolina, with the exception of certain legacies, amounting to less than $60,000, was devised…