United States Board of Tax Appeals December 9, 1927, Docket No. 7856. (United States Trust Co. v. Commissioner)

lead-opinion

*519OPINION.

Muedook:

At the hearing and in his brief counsel" for the petitioner mentioned some contention in regard to the executor’s demand for determination of the amount of tax and discharge from personal liability therefor in accordance with section 407 of the Revenue Act of 1921, but since no such issue was raised by the pleadings, we will dismiss the matter without further