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BANK v. COMMR. OF I. R.

No. 15607.

3 Ohio Misc. 189 (1964)

UNION COMMERCE BANK, TRANSFEREE, v. COMMR. OF INTERNAL REVENUE.

United States Court of Appeals, Sixth Circuit.

Decided December 14, 1964.

Attorney(s) appearing for the Case

Mr. James C. Davis, Mr. Warren E. Hacker, Mr. William H. Lutz, Jr., Mr. Stephen J. Alfred and Messrs. Squire, Sanders & Dempsey, for petitioner.

Mr. Gilbert E. Andrews, Mr. Louis F. Oberdorfer, Mr. Lee A. Jackson and Mr. Michael I. Smith, for respondent.

Before CECIL and EDWARDS, Circuit Judges, and TAYLOR, District Judge.

EDWARDS, C. J.

This appeal requires interpretation of Section 2036 (a) of the Internal Revenue Code of 1954 — the pertinent portions of which are quoted below:

"Transfers with retained life estate

"(a) General rule. — The value of the gross estate shall include the value of all property (except real property situated outside of the United States) to the extent of any interest therein of which the decedent has at any time...

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