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BOSTON SAFE DEPOSIT & T. CO. v. COMMISSIONER OF INT. REV.

No. 3342.

100 F.2d 266 (1938)

BOSTON SAFE DEPOSIT & TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

December 6, 1938.

Attorney(s) appearing for the Case

Charles M. Rogerson, of Boston, Mass. (Roger W. Hardy, of Boston, Mass., on the brief), for petitioner.

Louise Foster, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key, J. Louis Monarch, and John J. Pringle, Jr., Sp. Assts. to Atty. Gen., on the brief), for the Commissioner of Internal Revenue.

Before BINGHAM and WILSON, Circuit Judges, and PETERS, District Judge.

BINGHAM, Circuit Judge.

This is a petition to review an order or decision of the Board of Tax Appeals of January 14, 1938, determining a deficiency estate tax in the amount of $1,706.07, of which $1,554 is in dispute. The petitioner, a Massachusetts corporation, is the executor of the estate of Willard T. Carleton, late of Winchester, Mass., who died July 12, 1933. The facts in the case are not in dispute.

Carleton purchased insurance on his life in the amount...

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