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OWEN v. COMMISSIONER OF INTERNAL REVENUE

No. 6323.

53 F.2d 329 (1931)

OWEN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

October 26, 1931.

Attorney(s) appearing for the Case

Robert T. Jacob, of Portland, Or., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and J. Louis Monarch and A. H. Conner, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, and Prew Savoy, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C.), for respondent.

Before WILBUR and SAWTELLE, Circuit Judges, and WEBSTER, District Judge.

SAWTELLE, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals determining that a deficiency exists in estate taxes due from the estate of petitioner's intestate, under § 402(a) of the Revenue Act of 1921, 42 Stat. 227, 278, that provides:

"That the value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or...

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