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GUGGENHEIM v. HELVERING

No. 15.

117 F.2d 469 (1941)

GUGGENHEIM v. HELVERING, Com'r of Internal Revenue.

Circuit Court of Appeals, Second Circuit.

February 5, 1941.

Attorney(s) appearing for the Case

Montgomery B. Angell, of New York City, for petitioner.

Carlton Fox, Sp. Asst. to Atty. Gen., for respondent.

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

L. HAND, Circuit Judge.

This appeal is from an order of the Board of Tax Appeals assessing a deficiency in the estate tax due from the petitioner, as executrix of Daniel Guggenheim; the questions raised are of two kinds: (1) The proper value of items concededly includable in the gross estate; (2) whether certain items should be included at all. The first and most important of these is the proper value of the decedent's interest in what is described as the "Old Firm...

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