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SECOND NAT. BANK OF SAGINAW v. WOODWORTH

No. 6243.

66 F.2d 170 (1933)

SECOND NAT. BANK OF SAGINAW v. WOODWORTH, Collector of Internal Revenue.

Circuit Court of Appeals, Sixth Circuit.

June 30, 1933.

Attorney(s) appearing for the Case

George G. Witter, of Los Angeles, Cal. (Mark E. Mitchell and Theodore Benson, on the brief), for appellant.

Trent McMath, of Detroit, Mich. (Gregory H. Frederick, Charles B. W. Aldrich, and David A. Wolff, all of Detroit, Mich., and C. M. Charest, T. H. Lewis, Jr., and E. J. Dowd, all of Washington, D. C., on the brief), for appellee.

Before MOORMAN and HICKS, Circuit Judges, and NEVIN, District Judge.

MOORMAN, Circuit Judge.

Wellington R. Burt, a citizen of Michigan, died on March 2, 1919, and the Second National Bank of Saginaw, Mich., was nominated and qualified as executor of his will. On August 14, 1920, the bank filed a federal estate tax return, and the tax shown thereon was assessed and paid. Later the Commissioner increased the net value of the estate by adding thereto certain gifts made by the decedent during his life, and as a result assessed an additional...

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