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BELCHER v. COMMISSIONER OF INTERNAL REVENUE

No. 11931.

162 F.2d 974 (1947)

BELCHER v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

July 2, 1947.

Attorney(s) appearing for the Case

Al G. Rives and J. K. Jackson, both of Birmingham, Ala., for petitioner.

Melva M. Graney, Louise Foster, and George A. Stinson, Sp. Assts. to Atty. Gen., and Sewall Key, Acting Asst. Atty. Gen., J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and John M. Morawski, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and WALLER, Circuit Judges.

WALLER, Circuit Judge.

This is the case of another family partnership composed of the husband, his wife as trustee for their four minor children, and the wife individually, wherein the Tax Court found,1 with evidence to support its findings, that the husband [Taxpayer] had set up the four trusts and had then made gifts of the five partnership interests in his saw mill business to the members of his family for Federal income tax purposes...

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