SOPER, Circuit Judge.
This petition asks for a review of a decision of the Board of Tax Appeals wherein it was found that certain property held in trust by the Equitable Trust Company of New York was not subject to estate taxes as part of the estate of William M. Talbott, deceased, but belonged to Eleanor B. Talbott, his surviving wife. The contention of the Commissioner that there was a deficiency in estate taxes under the Revenue Act of 1926, as amended, 26 U.S...
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