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44 Stat affirmed agreement allowed amended amount assessment assets Asst bank beneficiary Board of Tax bonds cash cent certificates certiorari Circuit Court Circuit Judge claim for refund Commis Commissioner of Internal Company computing Congress Constitution corporation Court of Appeals David Gross decedent December 31 decision deduction defendant deficiency determined distribution District Court dividends employees entitled estate tax excise fact federal filed fund gross held Helvering income tax interest Internal revenue issued judgment L.Ed loss ment overpayment pany payment Petition for Review petitioner plaintiff poration preferred stock profits purchase purpose question received reorganization Revenue Act 1928 Robert H S.Ct Sewall Key sioner Social Security Act statute stockholders suit supra Tax Appeals tax imposed tax return taxable taxation taxpayer thereof tion title IX transfer Treasury trust United States Board University of Iowa York City