Earle v. Commissioner of Internal Revenue

This petition for review involves a deficiency in an estate tax determined by the Commissioner and sustained by the Tax Court against the estate of Emma Earle, deceased, and against G. Harold Earle and Stewart E. Earle, former executors, and residuary beneficiaries of the estate of Emma Earle,-whose liability either as fiduciaries or transferees is conceded for the taxes due from Emma Earle’s estate. A trust had been established by the will of George W. Earle in 1923, the important provision of which is as follows: “I further direct that the income accruing to said trust estate shall be…