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RAYMOND v. COMMISSIONER OF INTERNAL REVENUE

No. 7194.

114 F.2d 140 (1940)

RAYMOND v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

Rehearing Denied August 9, 1940.

Writ of Certiorari Denied December 9, 1940.

Attorney(s) appearing for the Case

Merritt C. Bragdon, James F. Oates, Jr., and Middleton Miller, all of Chicago, Ill. (Sidley, McPherson, Austin & Burgess, of Chicago, Ill., of counsel), for petitioner.

Samuel O. Clark, Jr., J. P. Wenchel, and Chas. E. Lowery, all of Washington, D. C., and Sewall Key, and Morton K. Rothschild, Sp. Assts. to Atty. Gen., for respondent.

Before EVANS, MAJOR, and TREANOR, Circuit Judges.

Writ of Certiorari Denied December 9, 1940. See 61 S.Ct. 319, 85 L.Ed. ___.

This appeal involves the extent of petitioner's liability, if any, for federal income tax, based on annuities paid to her by charitable institutions, pursuant to contract, the consideration for which was the payment of money allegedly in excess of the cost of the annuities.

Anna Raymond executed nine contracts with six charitable, educational or eleemosynary corporations, to whom she...

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