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FAIR v. COMMISSIONER OF INTERNAL REVENUE

No. 6361.

91 F.2d 218 (1937)

FAIR v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

June 2, 1937.

Attorney(s) appearing for the Case

Franklin F. Russell, of New York City, for petitioner.

James W. Morris, Asst. Atty. Gen., and Sewall Key, J., Louis Monarch and Joseph M. Jones, Sp. Assts. to Atty. Gen., for respondent.

Before BUFFINGTON and THOMPSON, Circuit Judges, and DICKINSON, District Judge.

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The petitioner is the executrix of the estate of William B. Fair, deceased. The decedent, a citizen of the State of New Jersey, died July 12, 1932. At the time of his death he was the owner of three hypotecas upon lands in Cuba. The Commissioner included the value of those hypotecas in the decedent's gross estate and assessed a deficiency. The applicable statute is section...

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