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REUTER v. COMMISSIONER OF INTERNAL REVENUE

No. 9774.

118 F.2d 698 (1941)

REUTER v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

March 15, 1941.

Attorney(s) appearing for the Case

Douglas D. Felix, of Miami, Fla., for petitioner.

Arthur A. Armstrong and Sewall Key, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau Int. Rev., and John W. Smith, Sp. Atty., Bureau Int. Rev. both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.

HOLMES, Circuit Judge.

This petition to review requires us to determine whether a conveyance in trust of the income from certain securities, made by the taxpayer to himself as trustee for the use and benefit of his wife, his father, and his mother, sufficiently alienated the title, possession, and control of the property from the grantor so as to relieve him from taxation upon the income thereof. To decide the question, we must analyze the terms and conditions of...

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