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UNITED STATES v. JACOBS

No. 391.

306 U.S. 363 (1939)

UNITED STATES v. JACOBS, EXECUTRIX.

Supreme Court of United States.

Decided February 27, 1939.

Attorney(s) appearing for the Case

Mr. Norman D. Keller argued the cause for the United States in No. 391 and respondent in No. 482. Solicitor General Jackson, Assistant Attorney General Morris, and Mr. Sewall Key were on the briefs for the United States in No. 391 and respondent in No. 482. Messrs. Carlton Fox and A.F. Prescott also were on the brief for the United States in No. 391. Messrs. Norman D. Keller and Edward J. Ennis also were on the brief for respondent in No. 482.

Mr. Hugh W. McCulloch, with whom Messrs. Frank H. McCulloch, Lewis C. Murtaugh, and Ned P. Veatch were on the brief, for respondent in No. 391.

Mr. E.J. Dimock, with whom Messrs. C.O. Donahue and J.D. Rawlings were on the brief, for petitioner in No. 482.

MR. JUSTICE BLACK delivered the opinion of the Court.

No. 391.

The question is whether the entire value or only one-half the value of real property — purchased by a decedent with his own funds and held at his death by his wife and himself under a joint tenancy set up prior to 1916 — may be included in the decedent's gross estate under the 1924 Revenue Act.

In 1909, real estate in Illinois was conveyed to W. Francis Jacobs, the decedent...

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