Avery Claflin and Philip A. Carroll, As Executors of Irene De Guebriant, Deceased, Petitioners, v. Commissioner of Internal Revenue, Respondent, 186 F.2d 307 (2d Cir. 1951)

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US Court of Appeals for the Second Circuit - 186 F.2d 307 (2d Cir. 1951) Argued January 3, 1951
Decided January 19, 1951

On petition to review an order of the Tax Court in banc assessing a deficiency in estate taxes for the year, 1945.

Shearman & Sterling & Wright and Paul R. Russell, all of New York City (Charles M. Baudinet, New York City, of counsel), for petitioner.

Charles Oliphant, Theron L. Caudle, Washington, D. C., George D. Webster, Washington, D. C., Ellis N. Slack, Sp. Asst. to Atty. Gen., for respondent.

Before L. HAND, Chief Judge, and SWAN and AUGUSTUS N. HAND, Circuit Judges.

PER CURIAM.


Order reversed and cause remanded for a redetermination of the amount of the tax liability on the authority of Jandorf's Estate v. Commissioner of Internal Revenue, 2 Cir., 171 F.2d 464 and Pennsylvania Company for Banking and Trusts v. United States, 3 Cir., 185 F.2d 125.

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