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PRICE v. COMMISSIONER OF INTERNAL REVENUE

No. 8958.

132 F.2d 95 (1942)

PRICE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

November 30, 1942.

Attorney(s) appearing for the Case

Homer E. Black and Albert B. Arbaugh, both of Canton, Ohio (Homer E. Black and Albert B. Arbaugh, both of Canton, Ohio, and Paul E. Shorb and Marion P. Wormhoudt, both of Washington, D. C., on the brief), for petitioner.

Carolyn E. Agger, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, J. Louis Monarch, and Carolyn E. Agger, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before SIMONS, MARTIN and McALLISTER, Circuit Judges.

MARTIN, Circuit Judge.

On petitions of H. C. Price for review of decisions of the United States Board of Tax Appeals, we must determine whether the income from a trust created by him was properly held taxable to him for 1934, 1935 and 1936, under Section 22(a) of the respective Revenue Acts of 1934 and 1936, 26 U.S.C.A. Int.Rev.Acts, pages 669, 825.

From the findings of fact of the Board of Tax Appeals, it appears that on October 1, 1923, the petitioner transferred...

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