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WILLIAMS v. UNITED STATES

69 F.Supp. 447 (1945)

WILLIAMS v. UNITED STATES.

District Court, S. D. New York.

May 9, 1945.

Attorney(s) appearing for the Case

Edward L. Blackman, of New York City, for plaintiff.

John F. X. McGohey, U. S. Atty., of New York City (Marvin M. Notkins, Asst. U. S. Atty., of New York City, of counsel), for defendant.

BRIGHT, District Judge.

Plaintiff seeks recovery of the amount paid by her under protest in settlement of a deficiency assessment of estate taxes upon the estate of her mother, Mary Clark deBrabant, deceased. The question to be decided is whether or not the corpus of an inter vivos trust, erected by decedent on February 6, 1928, should be included in the gross estate of the decedent under the provisions of § 811(c) of the Internal Revenue Code, 26 U.S.C.A. Int...

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