MOORE v. COMMISSIONER OF INTERNAL REVENUE

No. 47.

101 F.2d 704 (1939)

MOORE et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

February 6, 1939.


Attorney(s) appearing for the Case

Neil Burkinshaw and Edgar J. Goodrich, both of Washington, D. C. (Guggenheimer & Untermyer, of New York City, of counsel), for petitioner.

James W. Morris, Asst. Atty. Gen., and J. Louis Monarch and Helen R. Carloss, Sp. Assts. to Atty. Gen., for respondent.

Before MANTON, SWAN, and AUGUSTUS N. HAND, Circuit Judges.


MANTON, Circuit Judge.

The petitioner's decedent, on March 16, 1938, filed a petition for review of the decision of the United States Board of Tax Appeals, determining against her a deficiency in income tax for the calendar year 1931 of $7260.62. She died on July 30, 1938 and her executor appointed under her will continued the review.

Between June 16, 1926 and November 2, 1931, decedent made cash loans to the Oil Jack Co., Inc., aggregating $246,000. Promissory...

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