HANAUER'S ESTATE v. COMMISSIONER OF INTERNAL REV.

No. 218.

149 F.2d 857 (1945)

HANAUER'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

June 19, 1945.


Attorney(s) appearing for the Case

Harry J. Rudick and Morris L. Ernst, both of New York City, for petitioners.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, and Robert Koerner, Sp. Assts. to the Atty. Gen., for respondent.


HINCKS, District Judge.

This is a petition by the executors under the will of Jerome J. Hanauer to review a decision of the Tax Court sustaining a deficiency in the estate tax assessed against the estate which had resulted from the failure of the executors to include in the gross estate the value of the corpus of a trust created by the decedent's wife on June 3, 1932. On that day, the decedent and his wife had each transferred in trust a substantial portion of their...

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