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PHIPPS v. COMMISSIONER OF INTERNAL REVENUE

No. 56.

54 F.2d 469 (1931)

PHIPPS et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

December 7, 1931.

Attorney(s) appearing for the Case

Bernhard Knollenberg, of New York City, for petitioners.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, John H. McEvers, C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and J. E. Marshall, Sp. Atty., Bureau of Internal Revenue, all of Washington, D. C., for respondent.

Before MANTON, AUGUSTUS N. HAND, and CHASE, Circuit Judges.

AUGUSTUS N. HAND, Circuit Judge.

The taxpayers, who were two brothers and a sister, purchased a tract of land in 1916 at Palm Beach, Fla. They took the title in the name of an agent Robbins, had the tract surveyed, cleared, plotted into about seventy lots, ornamented with trees, and furnished with roads, water, sewers, and electric light. Soon after the lots were plotted, a price was fixed at which they might be sold at a...

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