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ANDERSON v. McNEIR

No. 139.

16 F.2d 970 (1927)

ANDERSON, Collector of Internal Revenue, v. McNEIR.

Circuit Court of Appeals, Second Circuit.

January 10, 1927.

Attorney(s) appearing for the Case

Emory R. Buckner, U. S. Atty., of New York City (Thomas J. Crawford and Edward Feldman, Asst. U. S. Attys., both of New York City, and Charles T. Hendler, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C., of counsel), for plaintiff in error.

Geller, Rolston & Blanc, of New York City (C. Alexander Capron and Russell L. Bradford, both of New York City, of counsel), for defendant in error.

Before MANTON and HAND, Circuit Judges, and CAMPBELL, District Judge.

MANTON, Circuit Judge.

During the calendar year of 1924, and prior to the passage of the Revenue Act of that year, the defendant in error made an irrevocable deed of trust to the Farmers' Loan & Trust Company, giving a large gift of securities for the benefit of his wife, children, and grand-children. The income from the corpus of this trust was to be paid to his wife and two children during the term of their lives. Trusts were created for grandchildren of the...

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