Rosenberg v. Commissioner of Internal Revenue

WILBUR, Circuit Judge.

Petitioner filed herein petition for review of the decision of the United States Board of Tax Appeals upholding the decision of respondent upon the taxation of the estate of Abraham Rosenberg, deceased.

The decedent died in San Francisco in 1929, leaving as survivors his widow, Alice J. Rosenberg, and one' daughter, Louise R. Bransten. His estate was distributed by the Superior Court in 1935, but the petitioner has not been discharged as administratrix with the will annexed. The estate was appraised at $2,283,348.18. It consisted principally of 17,400 shares of the…