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AMERICAN SECURITY & TRUST CO. v. DISTRICT OF COLUMBIA

No. 13042.

235 F.2d 19 (1956)

AMERICAN SECURITY AND TRUST COMPANY, Executor u/w of Florence Monfort Gheen, Deceased, Petitioner, v. DISTRICT OF COLUMBIA, Respondent.

United States Court of Appeals District of Columbia Circuit.

Decided May 17, 1956.

Attorney(s) appearing for the Case

Mr. Benton C. Tolley, Jr., Washington, D. C., with whom Mr. John E. Larson, Washington, D. C., was on the brief, for petitioner.

Mr. Leo J. Ehrig, Jr., Asst. Corp. Counsel for the District of Columbia, for respondent.

Messrs. Vernon E. West, Corp. Counsel, Chester H. Gray, Principal Asst. Corp. Counsel, and George C. Updegraff, Asst. Corp. Counsel, were on the brief for respondent.

Mr. George F. Donnella, Asst. Corp. Counsel, also entered an appearance for respondent.

Before EDGERTON, Chief Judge, and FAHY and BASTIAN, Circuit Judges.

PER CURIAM.

This case is before the court on a petition for review of a decision of the District of Columbia Tax Court, hereinafter referred to as the Tax Court.

The facts are undisputed and may be summarized as follows:

On February 9, 1953, the petitioner, as the executor of the estate of Florence Monfort Gheen, filed a federal estate tax return showing a gross estate of $552,184.90, which included the assets of an irrevocable trust created by the...

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