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UNITED STATES v. PROVIDENT TRUST CO. OF PENNSYLVANIA

No. 4009.

35 F.2d 339 (1929)

UNITED STATES v. PROVIDENT TRUST CO. OF PENNSYLVANIA et al.

Circuit Court of Appeals, Third Circuit.

October 3, 1929.

Attorney(s) appearing for the Case

George W. Coles, U. S. Atty., of Philadelphia, Pa. (C. M. Charest, Gen. Counsel, and T. H. Lewis, Jr., Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for the United States.

John S. Sinclair, Cuthbert H. Latta, Jr., and Charles Sinkler, all of Philadelphia, Pa., for appellees.

Before BUFFINGTON, WOOLLEY, and DAVIS, Circuit Judges.

WOOLLEY, Circuit Judge.

James K. Young and Mary Wilson Young, his wife, acquired as tenants by the entirety several parcels of real estate in Philadelphia. Later, they conveyed some of them for a consideration part paid and the balance secured by a ground rent, reserved to themselves as tenants by the entirety, to yield them a certain annual income, redeemable at a named figure.

James K. Young died in 1923. The Commissioner of Internal Revenue, upon review...

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