COMMISSIONER OF INTERNAL REVENUE
v.
KANN'S ESTATE et al.
United States Court of Appeals Third Circuit.https://leagle.com/images/logo.png
Argued December 9, 1948.
Decided April 19, 1949.
Attorney(s) appearing for the Case
Hilbert P. Zarky of Washington, D. C. (Theron Lamar Caudle, Asst. Atty. Gen., and Sewall Key and George A. Stinson, Sp. Assts. to the Atty. Gen., on the brief), for petitioner.
Ferdinand T. Weil of Pittsburgh, Pa. (F. T. Weil, S. Allen Vatz and Weil & Vatz, all of Pittsburgh, Pa., on the brief), for respondents.
Before BIGGS, Chief Judge, and McLAUGHLIN and O'CONNELL, Circuit Judges.
United States Court of Appeals Third Circuit.
BIGGS, Chief Judge.
Mrs. Bertha F. Kann, the decedent, sold certain securities to her children in return for their unsecured promises to pay her life annuities. The question presented for our determination is: Did the Tax Court err in holding1 that the decedent realized no taxable gain under Section 111(a) of the Internal Revenue Code, 26 U.S.C.A. § 111(a), and the applicable regulation on...
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