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SAFE DEPOSIT & TRUST CO. v. TAIT

No. 5149.

8 F.Supp. 634 (1934)

SAFE DEPOSIT & TRUST CO. OF BALTIMORE v. TAIT, Collector of Internal Revenue.

District Court, D. Maryland.

October 30, 1934.

Attorney(s) appearing for the Case

Charles McHenry Howard, of Baltimore, Md., for plaintiff.

John A. Rees and Julian G. Gibbs, Sp. Assts. to Atty. Gen., and Bernard J. Flynn, U. S. Atty., and G. Randolph Aiken, Asst. U. S. Atty., both of Baltimore, Md., for defendant.

CHESNUT, District Judge.

In this case the Safe Deposit and Trust Company of Baltimore sues, as surviving executor of Celeste M. W. Hutton, late of Baltimore City, deceased (who died February 25, 1925), to recover an alleged overpayment of federal estate taxes under the Estate Tax Act of 1924, c. 234 (43 Stat. 303, 304), which for the computation of the tax, provides that (section 302 (a, c), 26 USCA § 1094 note):

"The value of the gross estate of the...

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