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BROWN v. COMMISSIONER OF INTERNAL REVENUE

No. 4580.

50 F.2d 842 (1931)

BROWN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

June 23, 1931.

Attorney(s) appearing for the Case

Reynolds D. Brown, of Philadelphia, Pa., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and John H. McEvers and Sewall Key, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Robert L. Williams, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

THOMPSON, Circuit Judge.

This case is brought here upon petition for review of an order of redetermination entered by the Board of Tax Appeals.

Henry W. Brown on December 31, 1924, executed a deed of trust conveying and transferring a large part of his property to the Provident Trust Company and three of his sons as trustees. In the pertinent parts of the deed of trust, it was provided as follows:

"At the decease...

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