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OCR: 19 United States Jacobs, 908 U.S. 363 (1939) I1 Jacobs, joint tenancy for certain property had been created between husband and wife in 1909 before the fir'st estate tax was enacted in 191 Sae note supra. The husband died ir 1924. Because he had furnished the consideration the property, the gov ernnient sought to include the full value of the joint property ir the husband's gross estate. The estate argued that this represented an im proper retroa- tive" application of the estatc tax an interest cre ated before the tax was enacted. The Court rejecled that contention, conchuding that "the tax was not levied on the 1909 transfer and was not retroactivo" (id at 366) The Court noted that the estate tax was imposed on the change in ownership" that occurred in 1924. an that transpired after the e ...