Guinzburg v. Anderson

SWAN, Circuit Judge.

Henry A. Guinzburg died on November 16, 1928. Some fourteen months prior to his death he and his wife purchased and gave to their son on the occasion of his marriage a private residence in New York City, each of the donors paying one-half of the purchase price. The sum so paid by Mr. Guinzburg (less the statutory exemption of $5,000), the taxing officials assumed to include as part of his estate, thereby increasing the estate tax collected from the execu tors. The amount of the tax resulting from» the inclusion of such gift having been paid under protest and a claim for…