Tyler v. United States

WILLIAM C. COLEMAN,

District Judge. There are two questions presented by this proceeding: (1) Whether the value of shares of stock, acquired by a decedent and his wife as tenants by the entireties subsequent to the effective date of the Revenue Act of 1916 (39 Stat. 756) is to be included in the gross estate of such decedent for estate tax purposes under the provisions of that act; and (2), if so, whether such inclusion is constitutional.

The following facts appear from the statement which, by agreement, has been stipulated in the case: James E. Tyler, a resident of Baltimore, Md., died there…