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PROCTER v. COMMISSIONER OF INTERNAL REVENUE

No. 5390.

151 F.2d 603 (1945)

PROCTER v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

October 30, 1945.

Attorney(s) appearing for the Case

Thomas H. Fisher, of Chicago, Ill., for petitioner.

Carlton Fox, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and J. Louis Monarch, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before SOPER and DOBIE, Circuit Judges, and HARRY E. WATKINS, District Judge.

DOBIE, Circuit Judge.

This proceeding concerns a federal gift tax for the year 1939. The case was before us once before, when an elaborate opinion, written by Judge Parker, was filed. Again, on Procter's petition for rehearing, we filed a brief per curiam opinion, denying the petition. These opinions will be found in 4 cir., 142 F.2d 824, 154 A.L.R. 1215. Upon a remand by us, the Tax Court of the United States has determined a tax...

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