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COMMISSIONER v. ESTATE OF FIELD

No. 578.

324 U.S. 113 (1945)

COMMISSIONER OF INTERNAL REVENUE v. ESTATE OF FIELD.

Supreme Court of United States.

Decided February 5, 1945.

Attorney(s) appearing for the Case

Mr. L.W. Post, with whom Solicitor General Fahy, Assistant Attorney General Samuel O. Clark, Jr., Messrs. Sewall Key and J. Louis Monarch were on the brief, for petitioner.

Mr. Edgar J. Bernheimer, with whom Mr. Harry T. Zucker was on the brief, for respondent.

Mr. Charles Angulo, as amicus curiae, filed a brief on behalf of the estate of John C. Duncan.

MR. JUSTICE MURPHY delivered the opinion of the Court.

This is a companion case to Fidelity-Philadelphia Trust Co. v. Rothensies, ante, p. 108. It too presents a question as to the proper valuation of the corpus of an inter vivos trust under § 302 (c) of the Revenue Act of 1926, 44 Stat. 9, 70.

On June 8, 1922, the decedent transferred to a trustee certain assets valued at the date of his death at the sum of $157,452.82. The material...

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