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DU PONT v. COMMISSIONER OF INTERNAL REVENUE

No. 4620.

63 F.2d 44 (1933)

DU PONT v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Petition for Rehearing Withdrawn February 24, 1933.

Attorney(s) appearing for the Case

James S. Y. Ivins, of Washington, D. C. (C. R. Mudge, of Wilmington, Del., Kingman Brewster, O. R. Folsom-Jones, and Richard B. Barker, all of Washington, D. C., of counsel), for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and Hayner N. Larson, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and F. R. Shearer, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before DAVIS, Circuit Judge, and DICKINSON and McVICAR, District Judges.

DAVIS, Circuit Judge.

This is a petition for review from an order of redetermination of the Board of Tax Appeals involving income taxes for 1924, 1925, and 1926. 20 B. T. A. 482.

On September 18, 1923, the petitioner executed nine trust agreements for the benefit of his family. According to the terms of the agreements, he transferred thirty-two policies insuring his life, and certain shares of stock, to the trustee. The trustee agreed to apply the income from...

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