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HELVERING v. CITY BANK CO.

No. 10.

296 U.S. 85 (1935)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. CITY BANK FARMERS TRUST CO., TRUSTEE.

Supreme Court of United States.

Decided November 11, 1935.

Attorney(s) appearing for the Case

Mr. David E. Hudson, with whom Solicitor General Reed, Assistant Attorney General Wideman, and Mr. Sewall Key were on the brief, for petitioner.

Mr. Russell L. Bradford, with whom Messrs. Carl Taylor and George H. Craven were on the brief, for respondent.

MR. JUSTICE ROBERTS delivered the opinion of the Court.

The Revenue Act of 1926, § 302 (d),1 provides:

"The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated —

.....

"(d) To the extent of any interest therein of which the decedent has at any time made a transfer,...

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