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RICHARDSON v. COMMISSIONER OF INTERNAL REVENUE

Nos. 183, 184.

126 F.2d 562 (1942)

RICHARDSON v. COMMISSIONER OF INTERNAL REVENUE (two cases). COMMISSIONER OF INTERNAL REVENUE v. RICHARDSON (two cases).

Circuit Court of Appeals, Second Circuit.

Supplemental Opinion March 20, 1942.

Attorney(s) appearing for the Case

Carter, Ledyard & Milburn, of New York City (Leslie D. Dawson and Allin H. Pierce, both of New York City, of counsel), for taxpayers.

Samuel O. Clark, Jr., Asst. Atty. Gen., and J. Louis Monarch and Newton K. Fox, Sp. Assts. to the Atty. Gen., for Commissioner.

Before L. HAND, CHASE, and FRANK, Circuit Judges.

FRANK, Circuit Judge.

These cases are companions and were argued together. The evidence in the case of H. Smith Richardson and in that of Lunsford Richardson was substantially the same. We shall, for convenience, consider them together.1

Early in 1932, Lunsford Richardson and his brother, H. Smith Richardson, were the owners of many shares of Vick Financial Company, a Delaware Corporation...

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