COMMISSIONER OF INTERNAL REVENUE v. NEAL

No. 2780.

65 F.2d 761 (1933)

COMMISSIONER OF INTERNAL REVENUE v. NEAL et al.

Circuit Court of Appeals, First Circuit.

June 5, 1933.


Attorney(s) appearing for the Case

J. P. Jackson, Sp. Asst. to Atty. Gen. (Sewall Key and Francis H. Horan, Sp. Assts. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Brooks Fullerton, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for Commissioner of Internal Revenue.

Wm. Harold Hitchcock, of Boston, Mass., for Neal and others.

Before BINGHAM, WILSON, and MORTON, Circuit Judges.


BINGHAM, Circuit Judge.

This is a petition by the Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals holding that there was no deficiency in the income tax of the respondents, trustees of the First People's Trust, for the year 1924.

The First People's Trust was formed October 28, 1919, by a declaration of trust. It began business on January 1, 1920, and, before the time came for it to file an income tax return, submitted to the...

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