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BURNET v. HANLON

Nos. 3085, 3086.

51 F.2d 463 (1931)

BURNET, Commissioner of Internal Revenue, v. HANLON. SAME v. HENAGHAN.

Circuit Court of Appeals, Fourth Circuit.

June 27, 1931.

Attorney(s) appearing for the Case

J. Louis Monarch, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key and Andrew D. Sharpe, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and R. N. Shaw, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for petitioner.

George E. H. Goodner, of Washington, D. C., for respondents.

Before PARKER, Circuit Judge, and WATKINS and WEBB, District Judges.

WATKINS, District Judge.

In each of the two above-styled cases, the Commissioner of Internal Revenue has appealed from the decision of the Board of Tax Appeals reversing the assessment by the Commissioner of certain deficiency taxes against respondents. The cases are so related in fact and in law that they were consolidated for the hearing below, and were argued together on appeal.

On October 1, 1921, each of the respondents received as a gift, Mrs. Hanlon...

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