McWILLIAMS v. COMMISSIONER

No. 945.

331 U.S. 694 (1947)

McWILLIAMS v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided June 16, 1947.


Attorney(s) appearing for the Case

John A. Hadden argued the cause for petitioners. With him on the brief was John S. Beard, Jr.

Arnold Raum argued the cause for respondent. With him on the brief were Acting Solicitor General Washington, Sewall Key, Lee A. Jackson and Morton K. Rothschild.


MR. CHIEF JUSTICE VINSON delivered the opinion of the Court.

The facts of these cases are not in dispute. John P. McWilliams, petitioner in No. 945, had for a number of years managed the large independent estate of his wife, petitioner in No. 947, as well as his own. On several occasions in 1940 and 1941 he ordered his broker to sell certain stock for the account of one of the two and to buy the same number of shares of the same stock for the other, at as nearly the...

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