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MAHAFFEY v. HELVERING

No. 12648.

140 F.2d 879 (1944)

MAHAFFEY v. HELVERING, Com'r of Internal Revenue.

Circuit Court of Appeals, Eighth Circuit.

February 15, 1944.

Attorney(s) appearing for the Case

Henry J. Richardson, of Washington, D. C. (R. D. FitzGibbon, of St. Louis, Mo., on the brief), for petitioner.

S. Dee Hanson, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and A. F. Prescott, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before SANBORN, WOODROUGH, and RIDDICK, Circuit Judges.

RIDDICK, Circuit Judge.

The decision of the question presented on this petition to review a judgment of the United States Tax Court turns upon the effect, for purposes of income taxation, of transactions of petitioner, whereby he arranged for the payment of dividends on certain shares of corporate stock to his mother for her life. Apparently the parties agree that the precise question is whether the petitioner granted his mother a present irrevocable interest in the...

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