HELVERING v. SAFE DEPOSIT & TRUST CO. OF BALTIMORE

No. 4262.

95 F.2d 806 (1938)

HELVERING, Commissioner of Internal Revenue, v. SAFE DEPOSIT & TRUST CO. OF BALTIMORE.

Circuit Court of Appeals, Fourth Circuit.

April 5, 1938.


Attorney(s) appearing for the Case

Maurice J. Mahoney, Sp. Asst. to the Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to the Atty. Gen., on the brief), for petitioner.

Charles McH. Howard, of Baltimore, Md., for respondent.

Before PARKER, NORTHCOTT, and SOPER, Circuit Judges.


SOPER, Circuit Judge.

The petition for review presents two questions which arise in determining the value of the net estate of a decedent subject to the federal estate tax under sections 302 and 303 of the Revenue Act of 1926, 44 Stat. 9, 70, 72: (1) Whether the value of a block of shares of stock, on the date of decedent's death, must be determined by ascertaining the market value on that date of a single share, in accordance with Article 13 of Regulations 80 promulgated...

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