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LEVY'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 340.

65 F.2d 412 (1933)

LEVY'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

May 8, 1933.

Attorney(s) appearing for the Case

Saul I. Radin, of New York City (Otto C. Sommerich, of New York City, of counsel), for appellant.

Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Lewis S. Pendleton, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for appellee.

Before MANTON, SWAN, and AUGUSTUS N. HAND, Circuit Judges.

MANTON, Circuit Judge.

This petition seeks a review, pursuant to sections 1001-1003 of the Revenue Act of 1926 (44 Stat. 9, 109, 110 [26 USCA §§ 1224 and note, 1225, 1226]), of the imposition of a federal estate tax under the Revenue Act of 1924 (43 Stat. 253).

Joseph M. Levy died May 30, 1925, a resident of New York. By deed, dated June 5, 1914, there was conveyed to him and his wife, "their heirs and assigns...

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