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O'SHAUGHNESSY v. COMMISSIONER OF INTERNAL REVENUE

No. 5926.

60 F.2d 235 (1932)

O'SHAUGHNESSY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

June 27, 1932.

Attorney(s) appearing for the Case

Walter E. Barton, of Washington, D. C. (Joseph P. Tumulty and Timothy T. Ansberry, both of Washington, D. C., on the brief), for petitioner.

John MacC. Hudson, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, C. M. Charest, and Prew Savoy, all of Washington, D. C., on the brief), for respondent.

Before HICKS, HICKENLOOPER, and SIMONS, Circuit Judges.

SIMONS, Circuit Judge.

Petitioner seeks review of a decision of the Board of Tax Appeals affirming respondent's determination of a deficiency of $21,148.51 in federal estate tax under the Revenue Act of 1926, §§ 301 (a), 302, 302 (e), 302 (h) (26 USCA §§ 1092, 1094 (e, h), and the applicable regulations. Petitioner is the executrix of Peter O'Shaughnessy, who died August 1, 1926. On August 28, 1919, O'Shaughnessy and wife conveyed certain real...

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