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FIRST NAT. BANK IN DALLAS v. COMMISSIONER OF INT. REV.

No. 5863.

45 F.2d 509 (1930)

FIRST NAT. BANK IN DALLAS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

December 23, 1930.

Attorney(s) appearing for the Case

Rhodes S. Baker and Alex Weisberg, both of Dallas, Tex. (R. L. Guthrie and Thompson, Knight, Baker & Harris, all of Dallas, Tex., on the brief), for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and C. M. Charest, General Counsel, Bureau Internal Revenue, and Prew Savoy, Sp. Atty., Bureau Internal Revenue, both of Washington, D. C., and J. P. Jackson, Sp. Asst. to Atty. Gen. (J. P. Jackson, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before BRYAN and FOSTER, Circuit Judges, and DAWKINS, District Judge.

BRYAN, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals sustaining a deficiency assessment against the estate of Louis A. Pires, deceased. The Commissioner of Internal Revenue, in determining the amount of the assessment, included in the value of the estate the value of certain property, consisting of bank stock which within two years prior to his death Pires transferred to Elizabeth Bacon, and of an amount which he bequeathed in...

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