Estate of Frank D. Stranahan, Deceased v. Commissioner of Internal Revenue

PECK, Circuit Judge.

This appeal comes from the United States Tax Court, 1 which partially denied appellant estate’s petition for a re-determination of a deficiency in the decedent's income tax for the taxable period January 1, 1965 through November 10, 1965, the date of decedent’s death.

The facts before us are briefly recounted as follows: On March 11, 1964, the decedent, Frank D. Stranahan, entered into a closing agreement with the Commissioner of Internal Revenue Service (IRS) under which it was agreed that decedent owed the IRS $754,815.72 for interest due to deficiencies in federal…