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EDWARDS v. COMMISSIONER OF INTERNAL REVENUE

No. 1775.

102 F.2d 757 (1939)

EDWARDS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Tenth Circuit.

March 17, 1939.

Attorney(s) appearing for the Case

Wm. R. Baker, of Kansas City, Kan., for petitioner.

Oliver W. Hammonds, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PHILLIPS, BRATTON, and WILLIAMS, Circuit Judges.

PHILLIPS, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals involving income taxes of J. Renz Edwards for the year 1933.

For a number of years prior to January 18, 1929, petitioner and his father, F. S. Edwards, were the equal owners of and carried on a tobacco business at Kansas City, Kansas, under the name of F. S. Edwards Tobacco Company.

On January 18, 1929, they entered into a written contract, the material provisions...

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