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UNION TRUST CO. v. WARDELL

No. 236.

258 U.S. 537 (1922)

UNION TRUST COMPANY OF SAN FRANCISCO ET AL., AS EXECUTORS OF LACHMAN, v. WARDELL, UNITED STATES COLLECTOR OF INTERNAL REVENUE FOR THE FIRST DISTRICT OF CALIFORNIA, ET AL.

Supreme Court of United States.

Decided May 1, 1922.

Attorney(s) appearing for the Case

Mr. Garret W. McEnerney, with whom Mr. William D. Guthrie, Mr. E.S. Heller, Mr. Isaac Frohman and Mr. Bernard Hershkopf were on the brief, for plaintiffs in error.

Mr. James A. Fowler, Special Assistant to the Attorney General, with whom Mr. Solicitor General Beck was on the brief, for defendants in error.

Mr. Charles E. Hughes, Jr., and Mr. Allen S. Hubbard, by leave of court, filed a brief as amici curiae.

Mr. Mansfield Ferry, Mr. C. Alexander Capron and Mr. Russell L. Bradford, by leave of court, filed a brief as amici curiae.

Mr. J. Wallace Bryan and Mr. Charles McH. Howard, by leave of court, filed a brief as amici curiae.

MR. JUSTICE McKENNA delivered the opinion of the court.

This case was argued at the same time and submitted with No. 200, Shwab v. Doyle, just decided, ante, 529. It involves, as that case did, the Estate Tax Act of September 8, 1916, 39 Stat. 777, and its different facts illustrate and aid the principle upon which that case was decided.

Plaintiffs in error are executors of the last will and testament of Henriette S. Lachman, deceased...

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