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HELVERING v. ROBINETTE

Nos. 7894, 7895.

129 F.2d 832 (1942)

HELVERING v. Com'r of Internal Revenue, v. ROBINETTE. SAME v. PAUMGARTEN.

Circuit Court of Appeals, Third Circuit.

Decided March 23, 1942.

On Rehearing July 30, 1942.

Attorney(s) appearing for the Case

L. W. Post, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and J. Louis Monarch, Sp. Asst. to the Atty. Gen., on the brief), for petitioner.

Henry A. Mulcahy, of New York City, (John F. Kiernan, of New York City, on the brief) for respondents.

Before BIGGS, CLARK, and JONES, Circuit Judges.

CLARK, Circuit Judge.

In 1936 the younger respondent was contemplating marriage. To make sure that the family fortune would follow the line of descent the three trusts in the case at bar were established by her and her mother, the older respondent. By the terms of two of these instruments properties were irrevocably transferred to trustees by the daughter. Her trustees were to pay the entire income from the trusts to the...

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