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WHITMAN v. COMMISSIONER OF INTERNAL REVENUE

No. 117, Docket 21464.

178 F.2d 913 (1949)

WHITMAN v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided December 22, 1949.

Attorney(s) appearing for the Case

Watson Washburn, New York City, for petitioner.

Theron Lamar Caudle, Ellis N. Slack, Robert N. Anderson, C. Oliphant, Washington, D. C. (Morton K. Rothschild, Washington, D. C., of counsel), for respondent.

Before L. HAND, Chief Judge, and SWAN and FRANK, Circuit Judges.

The record facts and the Tax Court's findings and decision appear in that decision as reported in 12 T.C. 324.

FRANK, Circuit Judge.

The taxpayer, in 1943 and 1945, was not only the president and treasurer but also the holder of all but a few shares of the company's stock.1 In 1943, the company's directors, in a resolution awarding her $20,000, stated that this sum represented compensation for her...

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