GIANNINI v. COMMISSIONER OF INTERNAL REVENUE

No. 10829.

148 F.2d 285 (1945)

GIANNINI v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

Rehearing Denied April 9, 1945.


Attorney(s) appearing for the Case

George H. Koster and Bayley Kohlmeier, both of San Francisco, Cal., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, Eugene E. Beyer and John Costelloe, Sp. Assts. to the Atty. Gen., for respondent.

Before GARRECHT, STEPHENS, and HEALY, Circuit Judges.


STEPHENS, Circuit Judge.

The administrator of the estate of Virgil D. Giannini, deceased, petitioned the Tax Court for a redetermination of an assessed deficiency in estate taxes. The Tax Court found a deficiency in the sum of $25,515.86, and the administrator-taxpayer asks us to review the decision.

Prior to 1935 the Giannini family, composed of A. P. and Clorinda A., the mother and father, and their three children, L. M., Virgil D., and Clare Giannini Hoffman...

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