QUIGLEY v. COMMISSIONER OF INTERNAL REVENUE

No. 8388.

143 F.2d 27 (1944)

QUIGLEY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

June 8, 1944.


Attorney(s) appearing for the Case

Peter D. Quigley and William A. McSwain, both of Chicago, Ill., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., J. P. Wenchel, Bureau of Internal Revenue, of Washington, D. C., Carlton Fox, Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Asst. to the Atty. Gen., for respondent.

Before EVANS, SPARKS, and KERNER, Circuit Judges.


Commissioner charged petitioner, in determining her income tax liability, against her objection, with a $20,000 item, by her received in 1939. The correctness of this action determines the disposition of this appeal. Taxpayer contends that this sum was not income, but was received in compromise of her claim or right as an heir of her father's estate. She therefore contests the deficiency tax assessment for 1939 which Commissioner assessed against her on the theory...

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