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GOODMAN v. GRANGER

No. 12005.

243 F.2d 264 (1957)

Eleanor D. GOODMAN, Administratrix of the Estate of Jacques Blum, Deceased, Appellee, v. Stanley GRANGER, Collector of Internal Revenue For the 23rd Collection District of Pennsylvania, Appellant.

United States Court of Appeals Third Circuit.

Decided April 12, 1957.

Rehearing Denied May 2, 1957.

Attorney(s) appearing for the Case

M. Carr Ferguson, Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Attys., Dept. of Justice, Washington, D. C., D. Malcolm Anderson, Jr., U. S. Atty., Pittsburgh, Pa., on the brief), for appellant.

Charles E. Kenworthey, Pittsburgh, Pa. (Louis Caplan, J. Tomlinson Fort, Reed, Smith, Shaw & McClay, Pittsburgh, Pa., on the brief), for appellee.

Before GOODRICH, KALODNER and STALEY, Circuit Judges.

KALODNER, Circuit Judge.

When does the federal estate tax attach?

More specifically stated, when does such tax attach to a decedent-employee's contractual right to annual deferred compensation payments from his employer, payable to his estate after his death?

That problem, of first impression, is presented by this appeal by the government from a judgment in favor of the taxpayer, Eleanor D. Goodman, administratrix of the estate of Jacques Blum, deceased...

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