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UNITED STATES v. CARTWRIGHT

No. 71-1665.

411 U.S. 546 (1973)

UNITED STATES v. CARTWRIGHT, EXECUTOR.

Supreme Court of United States.

Decided May 7, 1973.

Attorney(s) appearing for the Case

Solicitor General Griswold argued the cause for the United States. With him on the brief were Assistant Attorney General Crampton, Richard B. Stone, Loring W. Post, and David English Carmack.

Ralph J. Gregg argued the cause for respondent. With him on the brief was George M. Zimmermann.*

MR. JUSTICE WHITE delivered the opinion of the Court.

The Internal Revenue Code of 1954 requires that, for estate tax purposes, the "value" of all property held by a decedent at the time of death be included in the gross estate. 26 U. S. C. § 2031. By regulation, the Secretary of the Treasury has determined that shares in open-end investment companies, or mutual funds, are to be valued at their public offering price or "asked" price at the date

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