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HELVERING v. HELMHOLZ

No. 6219.

75 F.2d 245 (1934)

HELVERING, Commissioner of Internal Revenue, v. HELMHOLZ.

United States Court of Appeals for the District of Columbia.

Decided December 31, 1934.

Attorney(s) appearing for the Case

Frank J. Wideman, Sewall Key, Robert H. Jackson, and Morton K. Rothschild, all of Washington, D. C., for petitioner.

James Quarles, of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.

GRONER, Associate Justice.

This case involves a deficiency assessment of estate taxes on the estate of Irene C. Helmholz, deceased.

Mrs. Helmholz died a resident of Wisconsin in 1927, and the applicable statute is the Revenue Act of 1926 (44 Stat. 9, §§ 301, 302 [26 USCA §§ 1092-1094]).

By a trust indenture dated June 7, 1918, and a supplemental indenture dated June 11, 1918, Mrs. Helmholz transferred to a corporate trustee 999...

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