United States v. Woodward, 256 U.S. 632 (1921)

United States v. Woodward


No. 811


Argued April 18, 1921
Decided June 6, 1921
256 U.S. 632

APPEAL FROM THE COURT OF CLAIMS

Syllabus

The Revenue Act of 1918, Title II, taxes by fixed percentages the net income "received by estates of deceased persons during the period of administration or settlement," and provides that the net income shall be ascertained by making from the gross income, as defined, certain deductions, including "taxes paid or accrued within the taxable year imposed by the authority of the United States, except income, war-profits and excess profits taxes."

Held:

(1) That "estate taxes," imposed by the Revenue Act of 1916 are among the taxes deductible. (See New York Trust Co. v. Eisner, ante,345.) P. 634.

(2) That an estate tax "accrued " when, by the terms of the Act of 1916, it became due, viz., one year from the decedent’s death, and, when paid by executors after the income tax year in which it accrued but before their return of income for that year was made or required, was properly deducted. P. 635.

56 Ct.Clms. 133 affirmed.

The case is stated in the opinion.