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SHUNK v. COMMISSIONER OF INTERNAL REVENUE

No. 10771.

173 F.2d 747 (1949)

SHUNK et al. v. COMMISSIONER OF INTERNAL REVENUE. SHUNK'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE. FEGLEY'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

April 4, 1949.

Attorney(s) appearing for the Case

J. Kenneth Baird, of Chicago, Ill., (K. Raymond Clark and J. Kenneth Baird, both of Chicago, Ill., on the brief), for petitioners.

Carlton Fox, of Washington, D. C. (Theron Lamar Caudle, Ellis N. Slack, and Louise Foster, all of Washington D. C., on the brief), for respondent.

Before ALLEN, MARTIN, and MILLER, Circuit Judges.

MILLER, Circuit Judge.

The petitioners seek separate reviews of three decisions of the Tax Court adjudging deficiencies in income tax for the calendar year 1940. The cases involve the same facts and are before us on a consolidated record. The question presented is whether property transferred by a trust estate, operating as a business, to a partnership formed by the beneficiaries of the trust estate, for an amount substantially less than its fair market value, constituted...

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