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TYLER v. UNITED STATES

No. 3240.

28 F.2d 887 (1928)

TYLER et al. v. UNITED STATES.

District Court, D. Maryland.

October 19, 1928.

Attorney(s) appearing for the Case

J. E. Tyler, Jr., of Baltimore, Md., and Frank S. Bright and Lowndes C. Connally, both of Washington, D. C., for plaintiffs.

Amos W. W. Woodcock, U. S. Atty., of Baltimore, Md., and C. M. Charest, General Counsel, Bureau of Internal Revenue, and J. D. Smith, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for the United States.

WILLIAM C. COLEMAN, District Judge.

There are two questions presented by this proceeding: (1) Whether the value of shares of stock, acquired by a decedent and his wife as tenants by the entireties subsequent to the effective date of the Revenue Act of 1916 (39 Stat. 756) is to be included in the gross estate of such decedent for estate tax purposes under the provisions of that act; and (2), if so, whether such inclusion is constitutional.

The following facts...

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