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JENNINGS v. SMITH

Civil Action No. 1007.

63 F.Supp. 834 (1945)

JENNINGS et al. v. SMITH, Collector of Internal Revenue.

District Court, D. Connecticut.

December 20, 1945.

Attorney(s) appearing for the Case

Marsh, Day & Calhoun and Philo C. Calhoun, all of Bridgeport, Conn., for plaintiffs.

Samuel O. Clark, Jr., Asst. Atty. Gen., Andrew D. Sharpe and Lester L. Gibson, Sp. Assts. to Atty. Gen., and Robert P. Butler, U. S. Atty., and Edward J. Lonergan, Asst. U. S. Atty., both of Hartford, Conn., for defendant.

HINCKS, District Judge.

The plaintiffs, executors of the will of Oliver Gould Jennings, paid the defendant, Collector of Internal Revenue for the District of Connecticut, an estate tax in the amount of $2,082,730.40 plus interest on certain deficiencies included therein. The executors had elected, under Section 811 (j) of the Internal Revenue Code, 26 U.S. C.A. Int.Rev.Code, § 811(j), to value the assets of the estate...

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