Nell La Compte Reaves, as of the Will of Jesse Ullman Reaves, Deceased v. Commissioner of Internal Revenue

JONES, Circuit Judge.

Jesse Ullman Reaves petitioned this Court to review and set aside a decision of the Tax Court finding deficiencies in his income tax and additions to tax for the years 1942 to 1947, inclusive. The Tax Court’s findings and opinion are reported in Reaves v. Commissioner, 31 T.C. 690. While the petition for review was pending Jesse Ullman Reaves died. On motion, Nell La Compte Reaves, as Executrix of the Will of Jesse Ullman Reaves, deceased, was substituted as Petitioner. For convenience we will herein refer to Jesse Ullman Reaves as the taxpayer.

The taxpayer was graduated…