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action affirmed agreement amended amount Amtorg assessed assets Asst beneficiary Circuit Court Circuit Judge Cite claim for refund Collector of Internal Commissioner of Internal community property Company computing contract corporation corpus Court of Appeals death decedent decedent's decision deduction defendant deficiency determined District Court dividends employees estate tax evidence excess profits tax excise tax F.Supp facts federal filed fund gift gift tax grantor gross estate Helvering income tax interest Internal Revenue Code issue judgment L.Ed lease liability lien ment partnership payment Petition to Review petitioner plaintiff preferred stock profits purchase question received reserve Revenue Act S.Ct Section securities settlor Sewall Key shares sioner statute Sun-Herald supra Tax Court tax purposes tax return taxable taxes paid taxpayer thereof tion transaction transfer trust trust instrument U. S. Atty U.S.C.A. Int.Rev.Acts U.S.C.A. Int.Rev.Code United wife