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CROCKER v. HELVERING

Nos. 6220, 6221.

76 F.2d 974 (1935)

CROCKER et al. v. HELVERING, Com'r of Internal Revenue. HELVERING, Com'r of Internal Revenue, v. CROCKER et al.

United States Court of Appeals for the District of Columbia.

Decided February 25, 1935.

Attorney(s) appearing for the Case

S. Milton Simpson, of Washington, D. C., and George E. Cleary, of New York City, for taxpayers.

Frank J. Wideman, Sewall Key, Milford S. Zimmerman, and Robert H. Jackson, all of Washington, D. C., for Commissioner of Internal Revenue.

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

MARTIN, Chief Justice.

These cross-appeals relate to alleged deficiencies in the federal estate tax due from the estate of Louis Joel Duveen, deceased, an alien nonresident who died on March 4, 1920.

It appears that on April 10, 1918, an agreement was executed by and between Henry J. Duveen of the city of New York, Joseph Duveen of the same place, Louis Joel Duveen of the city of London, and Benjamin Duveen of the city of New York, whereby it was agreed that...

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