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HARWICK v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12421, 12425, 12430, 12426, No. 12429.

133 F.2d 732 (1943)

HARWICK v. COMMISSIONER OF INTERNAL REVENUE. HELVERING, Com'r of Internal Revenue, v. DOBSON (two cases). DOBSON v. HELVERING, Com'r of Internal Revenue. HELVERING, Com'r of Internal Revenue, v. COLLINS' ESTATE.

Circuit Court of Appeals, Eighth Circuit.

March 2, 1943.

Attorney(s) appearing for the Case

S. Dee Hanson, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Helen R. Carloss, and Louise Foster, Sp. Assts. to Atty. Gen., were on the brief), for Commissioner of Internal Revenue.

John W. Windhorst, of Minneapolis, Minn. (Leland W. Scott and Fletcher, Dorsey, Barker, Colman & Barber, all of Minneapolis, Minn., on the brief), for the taxpayers.

Before SANBORN, WOODROUGH, and THOMAS, Circuit Judges.

THOMAS, Circuit Judge.

These cases come here upon petitions to review decisions of the United States Board of Tax Appeals. By order of court they have been consolidated for briefing, hearing, argument and decision.

Several years before the taxable year 1939, the four taxpayers, all residents of the state of Minnesota, had at various times individually purchased, in transactions entered into for profit, shares of the capital stock of the National City Bank...

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