People ex rel. Seligman v. Gilchrist

The issue herein arises in determining an income tax, and out of the disallowance of a deduction of $190,600.48 paid by the executors to the Federal collector of taxes August 4, 1922, the amount then assessed of the additional Federal estate tax. The facts are undisputed. The decedent, Isaac N. Seligman, died September 30, 1917. Each year thereafter the executors have made return for and paid the State income tax. They have uniformly kept their books for income tax purposes on a cash (receipt and payment) basis, not ah accrual basis. In April, 1923, they filed their income tax return for the…