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BROWN v. DEPUTY

No. 13.

30 F.Supp. 860 (1940)

BROWN v. DEPUTY, Collector of Internal Revenue.

District Court, D. Delaware.

January 4, 1940.

Attorney(s) appearing for the Case

Richards, Layton & Finger, of Wilmington, Del., for plaintiff.

Stewart Lynch, U. S. Atty., of Wilmington, Del., and Edward First, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. to Atty. Gen., and Andrew D. Sharpe, Sp. Asst. to Atty. Gen., on the brief), for defendants.

NIELDS, District Judge.

This action of assumpsit is to recover a gift tax of $16,370.90 with interest in the sum of $1,413.05, totaling $17,783.95 alleged to have been unlawfully assessed against plaintiff upon the transfer of eight single premium life insurance policies to Equitable Trust Company, as trustee, under a trust agreement dated December 13, 1935.

The Revenue Act of 1932, Ch. 209, 47 Stat. 169, as amended by the Revenue Act of 1934, 48 Stat. 680...

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