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COTTON v. COMMISSIONER OF INTERNAL REVENUE

Nos. 11506, 11507.

165 F.2d 987 (1948)

COTTON v. COMMISSIONER OF INTERNAL REVENUE. CALDWELL v. SAME.

Circuit Court of Appeals, Ninth Circuit.

Rehearing Denied March 9, 1948.

Attorney(s) appearing for the Case

A. Calder Mackay, Arthur McGregor, Howard W. Reynolds, and Adam Y. Bennion, all of Los Angeles, Cal., for petitioners.

Theron E. Caudle, Asst. Atty. Gen., Sewall Key, Lee A. Jackson, Morton K. Rothschild, and Newton Fox, Sp. Assts. to Atty. Gen., for respondent.

Before GARRECHT, MATHEWS, and ORR, Circuit Judges.

MATHEWS, Circuit Judge.

Here for review are decisions of the Tax Court that there were deficiencies in respect of taxes on gifts made by petitioners (Victoria L. Cotton and Virginia Caldwell) in 1941. Petitioner Cotton made a gift of 200 shares of stock of Carson Estate Company, hereafter called Carson, valued it at $250 a share and paid a gift tax computed on that basis. Petitioner Caldwell made a gift of 105 shares of stock of Francis Land Company, hereafter called...

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