TYSON v. COMMISSIONER OF INTERNAL REVENUE

No. 12922.

146 F.2d 50 (1944)

TYSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

December 20, 1944.


Attorney(s) appearing for the Case

H. M. Stolar, of St. Louis, Mo. (Jacob Chasnoff, Stanley S. Waite, and Lowenhaupt, Waite, Chasnoff & Stolar, all of St. Louis, Mo., were with him on the brief), for petitioner.

Bernard Chertcoff, Sp. Asst. to the Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Helen R. Carloss, and Leonard Sarner, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before SANBORN, THOMAS, and RIDDICK, Circuit Judges.


SANBORN, Circuit Judge.

This is a petition to review a decision of the Tax Court of the United States determining deficiencies in income taxes of the petitioner for the calendar years 1939 and 1940.

The question which this Court is called upon to decide is whether the determination by the Tax Court that what purport to be gifts by petitioner to his wife of certain "cash interests" in his business were not in fact valid and completed gifts, is as a matter of...

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