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SEWELL'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 11388.

151 F.2d 806 (1945)

SEWELL'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied December 28, 1945.

Attorney(s) appearing for the Case

O. C. Hancock and Clifford R. Wheeless, both of Atlanta, Ga., for petitioners.

John F. Costelloe, Sewell Key, and Helen R. Carloss, Sp. Ass'ts to Atty. Gen. and Samuel O. Clark, Jr., Asst. Atty. Gen., for respondent.

Before SIBLEY, McCORD, and WALLER, Circuit Judges.

McCORD, Circuit Judge.

The three Sewell Brothers, who owned virtually all the stock in the Sewell Manufacturing Company, a corporation engaged in the manufacture of men's and boys' clothing, entered into an agreement and made over to their wives by way of alleged gifts, certain stock in the corporation.

This appeal involves income tax liability of the estate of R. A. Sewell, deceased, for the calendar years 1934, 1935, 1936 and 1937. The questions presented...

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