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PARROTT v. COMMISSIONER OF INTERNAL REVENUE

No. 5310.

30 F.2d 792 (1929)

PARROTT et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

February 4, 1929.

Attorney(s) appearing for the Case

Knight, Boland & Christin and J. W. Radil, all of San Francisco, Cal., for plaintiffs in error.

Mabel Walker Willebrandt, Asst. Atty. Gen., and Sewall Key and Edwin G. Davis, Sp. Asst. Attys. Gen. (C. M. Charest, Gen. Counsel, and L. W. Scott, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for defendant in error.

Before GILBERT and DIETRICH, Circuit Judges, and NORCROSS, District Judge.

GILBERT, Circuit Judge.

The appellants' testatrix, Mary Emilie Parrott, was a resident of California at the time of her death on March 1, 1922. She owned an undivided one-half interest in certain real estate in San Francisco, the value of which interest was computed in her gross estate at $315,750. Her interest at the time of her death was subject to a mortgage of $260,000, given on December 30, 1920, to secure a note and mortgage of that date. The note was the joint...

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