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COMMISSIONER OF INTERNAL REVENUE v. PUPIN'S ESTATE

No. 85.

107 F.2d 745 (1939)

COMMISSIONER OF INTERNAL REVENUE v. PUPIN'S ESTATE et al.

Circuit Court of Appeals, Second Circuit.

November 20, 1939.

Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Louise Foster, Sp. Assts. to Atty. Gen., for petitioner.

Harry W. Forbes, of New York City, for respondent.

Before L. HAND, AUGUSTUS N. HAND, and PATTERSON, Circuit Judges.

PATTERSON, Circuit Judge.

The question is whether the estate of Michael I. Pupin, deceased, is liable for additional estate tax. The decedent died in 1935, leaving an estate subject to estate tax. During his lifetime he had taken out policies of insurance on his life. Insurance of a value of $51,122.20 was payable to his daughter. Other insurance, $50,000 in amount, was payable to Columbia University. By section 302 of the...

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