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ESTATE OF PUTNAM v. COMM'R.

No. 534.

324 U.S. 393 (1945)

ESTATE OF PUTNAM; GUARANTY TRUST CO., EXECUTOR, v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided March 26, 1945.

Attorney(s) appearing for the Case

Mr. Wm. Dwight Whitney, with whom Messrs. Robert T. Swaine, Roswell Magill and George G. Tyler were on the brief, for petitioner.

Miss Helen R. Carloss, with whom Solicitor General Fahy, Assistant Attorney General Samuel O. Clark, Jr., Messrs. Sewall Key, Robert N. Anderson, Walter J. Cummings, Jr. and Miss Helen Goodner were on the brief, for respondent.

MR. JUSTICE REED delivered the opinion of the Court.

This case brings here for review a judgment which applies Section 42, Revenue Act of 1938,1 so as to "accrue" corporate dividends on the date of their declaration rather than the later record or payment dates. The result is that the dividends are taxable as income to a decedent taxpayer instead of to his estate.

Certiorari was granted2 because of...

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