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EGGLESTON v. DUDLEY

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF PENNSYLVANIA


March 29, 1957

Edward J. EGGLESTON and Sadye J. DeRoy Silverman, Executors under the Last Will and Testament of Emanuel I. DeRoy, Deceased,
v.
A. J. DUDLEY, District Director of Internal Revenue, Philadelphia Region

The opinion of the court was delivered by: MCILVAINE

The above entitled cause came on regularly for trial and the Court having duly considered the evidence and being fully advised in the premises now finds the following:

Findings of Fact

 1. This action arises under the Internal Revenue Code of the United States as amended.

 2. Defendant was the District Director of Internal Revenue for the Pittsburgh District of the Philadelphia Region.

 3. Emanuel I. DeRoy died a resident of Cambria County, Pennsylvania, on October 13, 1950, and by his last will and testament, duly probated in the Office of the Register of Wills of said county and recorded in Will Book, Volume 25, at page 307, appointed Edward J. Eggleston and Sadye J. DeRoy as executors of said will. Said executors duly qualified to act as such before said Register of Wills and thereafter the said Sadye J. DeRoy intermarried with Benjamin Silverman and is now known as Sadye J. DeRoy Silverman.

 4. On or about the 23rd day of November, 1951, plaintiffs filed their federal estate tax return for said decedent's estate and paid the tax shown thereby, to wit, $ 28,419.80.

 5. On or about September 13, 1954, T. Coleman Andrews, Commissioner of Internal Revenue Service, by A. J. Dudley, District Director of Internal Revenue, sent a letter to Edward J. Eggleston, one of the plaintiffs herein, as coexecutor, proposing a deficiency tax of $ 15,627.26. By letter dated October 8, 1954, the District Director advised plaintiffs that the estate was allowed a credit against said deficiency in the amount of $ 2,187.77. The deficiency letter referred to contained the following reason for the assessment of a deficiency tax, to wit: "Schedule M -- Marital Return Company Determined Deduction Item 2 1026.11 Equitable Exhibit A Item 3 5017.35 Equitable Exhibit B Item 4 3031.81 Equitable Exhibit C Item 5 7020.28 Equitable Exhibit D Item 6 2013.80 Equitable Exhibit D Item 7 1019.34 Equitable Exhibit E Item 8 2000.00 Equitable Exhibit F Item 9 3000.00 Equitable Exhibit G Item 10 7179.78 Equitable Exhibit H Item 11 16540.99 Equitable Exhibit I Item 12 25623.86 Equitable Exhibit 5 Item 13 25590.20 Equitable Exhibit 4

19570329

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