FARMERS' LOAN & TRUST CO. v. BOWERS

Nos. 101, 102.

68 F.2d 916 (1934)

FARMERS' LOAN & TRUST CO. v. BOWERS (two cases).

Circuit Court of Appeals, Second Circuit.

January 8, 1934.


Attorney(s) appearing for the Case

George Z. Medalie and Thomas E. Dewey, U. S. Attys., both of New York City (Samuel C. Coleman, Frank Chambers, Ralph E. Stone, and Ira Koenig, Asst. U. S. Attys., all of New York City, William Stanley, Asst. to Atty. Gen., and Carlton Fox, Sp. Asst. to Atty. Gen., of counsel), for appellant.

Taylor, Blanc, Capron & Marsh, of New York City (John W. Davis, Carl Taylor, Charles Angulo, and Russell L. Bradford, all of New York City, of counsel), for appellees.

Before MANTON, L. HAND, and CHASE, Circuit Judges.


MANTON, Circuit Judge.

These actions, tried together before a court without a jury, will be considered in one opinion. The actions are by the trustee under two deeds of trust made by William Waldorf Astor, in his lifetime, to recover from the appellant the estate taxes paid to appellant as a result of the inclusion of the corpus of the trusts in the estate of Astor after his death. The tax was levied on two irrevocable trusts of realty in the United States, executed...

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