District of Columbia v. Marion Woodward Payne

*263BASTIAN, Senior Circuit Judge:

This matter is before us on petition for review of a decision of the District of Columbia Tax Court. The case involves an inheritance tax levied on respondent, Marion Woodward Payne, as residuary legatee of the estate of Henry Sterne Woodward, deceased.

The District of Columbia first claims that the Tax Court was without jurisdiction to entertain the appeal from the assessment of the inheritance tax in question. The second claim has to do with the substantive questions involved in the assessment of the tax.

We turn first to the question of jurisdiction. The facts…