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UNITED STATES v. MITCHELL

No. 470.

271 U.S. 9 (1926)

UNITED STATES v. MITCHELL ET AL., EXECUTORS.

Supreme Court of United States.

Decided April 12, 1926.

Attorney(s) appearing for the Case

Solicitor General Mitchell, with whom Messrs. A.W. Gregg, Solicitor of Internal Revenue, and T.H. Lewis, Jr., were on brief, for the United States.

Mr. A.L. Humes, with whom Mr. Stafford Smith was on the brief, for appellees.

MR. JUSTICE BUTLER delivered the opinion of the Court.

November 28, 1918, Dellora R. Gates, a resident of Texas, died testate; and, January 6, 1919, the County Court of Jefferson County granted letters testamentary to appellees. The federal estate tax accrued one year after her death; and, November 26, 1919, the executors made a return showing $2,927,762.64 due the United States under the Revenue Act of 1916.1 They did not pay any part...

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