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HORNOR'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

Nos. 7915, 7969.

130 F.2d 649 (1942)

HORNOR'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE. COMMISSIONER OF INTERNAL REVENUE v. HORNOR'S ESTATE.

Circuit Court of Appeals, Third Circuit.

Decided August 21, 1942.

Attorney(s) appearing for the Case

F. Raymond Wadlinger, of Philadelphia, Pa. (Foulkrod, Sheppard, Porter & Alexander, of Philadelphia, Pa., on the brief), for taxpayer.

Morton K. Rothschild, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to the Atty. Gen., on the brief), for Commissioner.

Before BIGGS, MARIS, and GOODRICH, Circuit Judges.

BIGGS, Circuit Judge.

William MacPherson Hornor died on January 18, 1937, and his widow, Julia C. Hornor, the executrix of his estate, filed a federal estate tax return at Philadelphia. The decedent owned 107 parcels of real estate in and about Philadelphia. The greater part of these were acquired by him by devise from his mother. He purchased the rest. During the years 1925 to 1935, inclusive, he conveyed all of these properties to himself and his wife as tenants...

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