MOORMAN, Circuit Judge.
Bernard Wurzburger and his wife, Laura Wurzburger, were residents of Michigan from 1910 until his death on July 10, 1925. Prior to September 8, 1916, the effective date of the first federal estate tax (39 Stat. 777), they acquired two pieces of real estate as tenants by the entirety. Upon the death of the husband the Commissioner assessed an estate tax against the properties. The Board of Tax Appeals affirmed (21 B. T. A. 1373), and the petitioner...
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