HELVERING v. SAFE DEPOSIT & TRUST CO.

No. 4750.

121 F.2d 307 (1941)

HELVERING, Com'r of Internal Revenue, v. SAFE DEPOSIT & TRUST CO. OF BALTIMORE et al.

Circuit Court of Appeals, Fourth Circuit.

June 10, 1941.


Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Asst. Atty. Gen. (Sewall Key, Arthur A. Armstrong, and Richard H. Demuth, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

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

Before PARKER, SOPER, and NORTHCOTT, Circuit Judges.


PARKER, Circuit Judge.

This is a petition by the Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals with respect to estate tax alleged to be due by the estate of the late Zachary Smith Reynolds. The decision of the Board is reported in 42 B.T.A. 145. Many contentions pressed before the Board have been abandoned in the petition here. Only two questions are before us: (1) whether decedent had such an interest in the property embraced in...

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