LEVY v. WARDELL

No. 303.

258 U.S. 542 (1922)

LEVY ET AL. 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. Edward F. Treadwell 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. JUSTICE McKENNA delivered the opinion of the court.

The case was determined in the court below upon demurrer to the complaint. The complainant alleged that on the 19th day of December, 1902, and for sometime prior thereto, Henriette Levy was the owner of 22,014 shares of the capital stock of the Levy Estate Company, a corporation. On that date she conveyed to the plaintiffs Harriet L. Levy, Pauline Jacobs and Adeline Salinger, each 5,000 shares of that stock....

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