COMMISSIONER OF INTERNAL REVENUE v. BACHRACH

Nos. 10062-10064.

182 F.2d 261 (1950)

COMMISSIONER OF INTERNAL REVENUE v. BACHRACH. COMMISSIONER OF INTERNAL REVENUE v. UHLMANN. COMMISSIONER OF INTERNAL REVENUE v. BENJAMIN.

United States Court of Appeals Seventh Circuit.

May 12, 1950.


Attorney(s) appearing for the Case

Theron L. Caudle, Assistant Attorney General, Ellis N. Slack, Melva M. Graney, A. F. Prescott, Edward J. P. Zimmerman, Special Assistants to Attorney General, for petitioner.

Walter Bachrach, Morris Solomon, Chicago, Illinois, Hazel Sheffner, Chicago, Illinois, for respondents.

Before MAJOR, Chief Judge, and KERNER and DUFFY, Circuit Judges.


MAJOR, Chief Judge.

These are petitions for review of the decisions of the Tax Court and involve deficiencies in income tax for the taxable year 1944. The questions for decision are the same and stem from identical facts. They were consolidated before the Tax Court for hearing and decision.

Two issues are presented for decision: (1) whether the exchange by taxpayers of second mortgage bonds issued by the Standard Club for certificates of indebtedness pursuant...

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