LEE v. COMMISSIONER OF INTERNAL REVENUE

No. 8491.

143 F.2d 4 (1944)

LEE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

June 21, 1944.


Attorney(s) appearing for the Case

Samuel E. Hirsch, Julian H. Levi, and William Ruger, all of Chicago, Ill., for petitioner.

J. P. Wenchel and John W. Smith, Bureau of Internal Revenue, both of Washington, D. C., and Samuel O. Clark, Jr., Sewall Key, J. Louis Monarch, and L. W. Post, Department of Justice, all of Washington, D. C., for respondent.

Before EVANS, SPARKS, and MAJOR, Circuit Judges.


SPARKS, Circuit Judge.

The taxpayer petitions for review of a decision of the Tax Court holding him liable for the income taxes assessed on the dividends received by a trustee upon certain shares of stock which constituted the corpus of its trust.

The controversy arises as the result of an arrangement whereby the owner of practically all of the stock of a corporation sought to provide by trust instrument that upon his death, the value of the stock of the corporation...

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