The Second National Bank of New Haven, of the Will of Frederick F. Brewster, Late of Hamden, Deceased v. United States

RYAN, District Judge:

This appeal presents a narrow issue requiring the interpretation of Section 2011(a) of the 1954 Internal Revenue Code, to determine the proper credit for State death taxes against the federal estate tax.1 The question posed is: do the words “gross estate” in the statute mean gross estate for federal estate tax purposes, or do they mean gross estate used by a State in arriving at its inheritance or succession tax. Put another way, we are asked whether an estate may credit against federal estate taxes, death taxes paid to a State on property included in the State return but…