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IN RE HILL'S ESTATE

No. 36, Docket 22024.

193 F.2d 724 (1952)

In re HILL'S ESTATE. BODINE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided January 22, 1952.

Attorney(s) appearing for the Case

Montgomery B. Angell and John A. Reed, New York City, for petitioner.

Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack and Hilbert P. Zarky, Sp. Assts. to Atty. Gen., Charles Oliphant, Washington, D. C., for respondent.

Before SWAN, Chief Judge, FRANK, Circuit Judge, and COXE, District Judge.

SWAN, Chief Judge.

This appeal involves a deficiency in the federal estate tax assessed against the estate of Walter J. Hill, deceased. Section 811(a) of the Internal Revenue Code, 26 U.S.C.A. § 811(a), requires that there be included in the gross estate of a decedent "the value at the time of his death of all property * * * to the extent of the interest therein of the decedent at the time of his death".1 On January 2, 1919, Mr. Hill...

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