PHIPPS v. COMMISSIONER OF INTERNAL REVENUE

No. 2371.

127 F.2d 214 (1942)

PHIPPS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Tenth Circuit.

March 23, 1942.


Attorney(s) appearing for the Case

David A. Reed, of Pittsburgh, Pa. (Fred T. Ikeler, Thomas P. Johnson, and Reed, Smith, Shaw & McClay, all of Pittsburgh, Pa., on the brief), for petitioner.

Joseph M. Jones, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and J. Louis Monarch, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PHILLIPS, BRATTON, and HUXMAN, Circuit Judges.


HUXMAN, Circuit Judge.

This appeal involves the assessment of deficiency gift taxes in the amount of $21,143.90 for the year 1935. Two questions are presented for consideration: First, whether taxpayer was entitled in his return for 1935 to claim any part of the statutory exemption of $50,000.00;1 and, Second, whether there was substantial evidence to sustain the Board's valuation placed on 10,000 shares of cumulative preferred stock of...

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