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COMMISSIONER OF INTERNAL REVENUE v. BURDETTE

No. 7134.

69 F.2d 410 (1934)

COMMISSIONER OF INTERNAL REVENUE v. BURDETTE.

Circuit Court of Appeals, Ninth Circuit.

February 23, 1934.

Attorney(s) appearing for the Case

John H. McEvers and Walter L. Barlow, Sp. Assts. to Atty. Gen., for petitioner.

Thomas R. Dempsey and A. Calder Mackay, both of Los Angeles, Cal. (Howard W. Reynolds, of Los Angeles, Cal., of counsel), for respondent.

Before SAWTELLE and GARRECHT, Circuit Judges, and NORCROSS, District Judge.

GARRECHT, Circuit Judge.

On May 1, 1915, the respondent loaned to her son, Roy Bradley Wheeler, the sum of $25,700. He executed in her favor two notes, each payable "Thirty days after demand," one for $17,700, with interest at the rate of 6 per cent., and one for $8,000, with interest at the rate of 6½ per cent., and he deposited with her as collateral security certificates for 400 shares of corporation stock in the Torrence-Marshall & Co. In 1922, while...

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