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STIMPSON v. COMMISSIONER OF INTERNAL REVENUE

No. 9219.

55 F.2d 815 (1932)

STIMPSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

Rehearing Denied March 1, 1932.

Attorney(s) appearing for the Case

William M. Fitch, of St. Louis, Mo. (George H. Moore, of St. Louis, Mo., on the brief), for petitioner.

Norman D. Keller, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Hartford Allen, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before VAN VALKENBURGH, BOOTH, and GARDNER, Circuit Judges.

BOOTH, Circuit Judge.

This is a petition for review of an order of the Board of Tax Appeals entered September 30, 1930, as amended by an order of February 12, 1931, redetermining deficiencies in the income taxes of petitioner for the calendar years 1922, 1923, and 1924. The two latter years only are here involved.

The question presented is whether certain transactions by petitioner relative to securities owned by her were sales of said securities resulting...

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