DICKEY v. BURNET

No. 8963.

56 F.2d 917 (1932)

DICKEY et al. v. BURNET, Commissioner of Internal Revenue.

Circuit Court of Appeals, Eighth Circuit.

Rehearing Denied April 22, 1932.


Attorney(s) appearing for the Case

Maurice H. Winger and Alton Gumbiner, both of Kansas City, Mo. (Winger, Reeder, Barker, Gumbiner & Hazard, of Kansas City, Mo., on the brief), for petitioners.

John G. Remey, 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 Dean P. Kimball, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before STONE and VAN VALKENBURGH, Circuit Judges, and SANBORN, District Judge (since appointed Circuit Judge).


SANBORN, Circuit Judge.

The executors of the last will and testament of Walter S. Dickey, deceased, petition for a review of an order of the Board of Tax Appeals determining deficiencies in the individual income taxes of Mr. Dickey for the years 1920 and 1921 of $167,285.10 and $97,669.27, respectively.

In 1917, Mr. Dickey, who resided in Kansas City, Mo., was a man of large means and varied business interests. He was engaged, among other things, in the manufacture...

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