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HELVERING v. SAFE DEPOSIT CO.

No. 600.

316 U.S. 56 (1942)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. SAFE DEPOSIT & TRUST CO. OF BALTIMORE, TRUSTEE, ET AL.

Supreme Court of United States.

Decided April 13, 1942.

Attorney(s) appearing for the Case

Assistant Attorney General Clark, with whom Solicitor General Fahy and Messrs. J. Louis Monarch, Richard H. Demuth, and Arthur A. Armstrong were on the brief, for petitioner.

Mr. Charles McH. Howard for respondents.

MR. JUSTICE BLACK delivered the opinion of the Court.

Because of the importance in the administration of the Federal Estate Tax of the questions involved, we granted certiorari to review the judgment of the Circuit Court of Appeals, 121 F.2d 307, affirming a decision of the Board of Tax Appeals, 42 B.T.A. 145.

Zachary Smith Reynolds, age 20, died on July 6, 1932. At the time, he was beneficiary of three trusts: one created...

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