Robinette v. Commissioner of Internal Revenue

HICKS, Circuit Judge.

Petition by Lenore S. Robinette, a transferee of the transferee of the assets of the taxpayer, Charles C. Cohn, deceased. It is to review a decision of the Board of Tax Appeals affirming the action of the Commissioner of Internal Revenue in assessing against petitioner a deficiency in income tax for 1918 due from the original transferor, Cohn, in the sum of $27,914.38, with interest.

The facts as stipulated and as found by the Board are briefly as follows:

Charles C. Cohn, a citizen of the United States, resided in the Philippine Islands from 1903 until 1919. He practiced…