Appeal from the District Court of the United States for the District of Connecticut.
Before L. HAND, AUGUSTUS N. HAND, and CHASE, Circuit Judges.
AUGUSTUS N. HAND, Circuit Judge.
The plaintiffs are the executors of the will of Alice E. Kingsbury, who died on April 4, 1937. They filed a federal estate tax return on July 2, 1938, reporting a tax liability for the estate in the amount of $134,450.21, which was paid on July 2, 1938. The property of the estate was valued as of April 4, 1938, under the election of the taxpayers to have the property valued as of one year after the death of the decedent pursuant to the option granted by Section 202 of the Revenue Act of 1935, 26 U.S.C.A. Int. Rev. Acts, page 805.
At the time of the decedent's death she owned the following securities which the executors reported in their return:
Shares Per Share According to
Shares Owned by Market Plaintiffs'
Name of Company Outstanding This Estate Quotations Expert
Bridgeport Brass Co. 926,900 15,180 $6 5/8 5 5/8 to $6
Insurance Co. 300,000 600 45 1/4 40
Illuminating Shares Co. 1,158,966 800 46 ...