WALLER, Circuit Judge.
The chief question involved in this case is whether or not a declaratory judgment of a state court, rendered after a federal income tax liability had accrued, in a case in which neither the Collector nor the Commissioner of Internal Revenue was a party, is res judicata in a suit in the Federal Court involving such income tax liability.
The income tax consequences to donors or to trustees are not always controlled by the sole incidence...
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