Smith v. Gowan-Stobo's Estate

Curtis, J. —

This was an action by Will H. Smith, Collector of Internal Revenue for the Collection District of Indiana, against the estate of John Gowan-Stobo and George B. Foster, as administrator of such estate, for the allowance of a claim for a deficiency in- income tax for the year of 1932, alleged to have been assessed by the Commissioner of Internal Revenue.

The government’s original claim was composed of two items, the first being a balance due on deceased’s income tax return for the year of 1935, which claim was allowed and is not now in issue. The second item of the claim represents…