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PENN v. COMMISSIONER OF INTERNAL REVENUE.

No. 11559.

109 F.2d 954 (1940)

PENN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

March 7, 1940.

Attorney(s) appearing for the Case

A. F. Schaetzle, of Des Moines, Iowa, for petitioner.

Edward H. Hammond, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before STONE, SANBORN, and THOMAS, Circuit Judges.

THOMAS, Circuit Judge.

This petition to review a decision of the United States Board of Tax Appeals involves the income taxes of petitioner for the years 1934 and 1935. The question presented is whether the petitioner is taxable for the income derived from securities constituting the corpus of two trusts of which he was grantor and trustee and his two minor daughters were the beneficiaries.

The taxpayer is a resident of Des Moines, Iowa. On June 7, 1934, he...

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