HUTCHESON, Circuit Judge.
An appeal from the decision of the Board of Tax Appeals, 29 BTA 53, this case involves a deficiency in estate taxes imposed under the Revenue Act of 1926, on account of life insurance policies Edgar Newman had taken out in favor of his wife, Elsa Schwartz Newman, as beneficiary. The Board made findings of fact in substance as follows:
"The petitioners are the duly qualified executors of the estate of Edgar Newman, who died in New...
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