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JEFFRIES v. COMMISSIONER OF INTERNAL REVENUE

No. 11646.

158 F.2d 225 (1946)

JEFFRIES v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied December 24, 1946.

Writ of Certiorari Denied March 31, 1947.

Attorney(s) appearing for the Case

J. Mark Wilcox, of Miami, Fla., for petitioner.

Helen Goodner and Robert N. Anderson, Sp. Assts. to Atty. Gen., both of Washington, D. C., Sewall Key, Acting Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bur. Int. Rev., and Charles E. Lowery, Sp. Atty., Bur. Int. Rev., both of Washington, D. C., for respondent.

Before SIBLEY, HUTCHESON, and WALLER, Circuit Judges.

HUTCHESON, Circuit Judge.

In 1940, petitioner was the owner of half the stock, and president, of Girard Realty Co. In that year, pursuant to an arrangement made between her and the owners of the other half of the stock, the corporation transferred to petitioner one-half of its lands and property, and petitioner surrendered to the corporation for cancellation her one-half of the stock. Considering the property received by her in exchange for the stock as received in...

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