GOOLD v. COMMISSIONER OF INTERNAL REVENUE

No. 12296.

182 F.2d 573 (1950)

GOOLD v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Ninth Circuit.

May 4, 1950.


Attorney(s) appearing for the Case

Lafayette J. Smallpage, Stockton, Cal., for petitioner.

Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, A. F. Prescott, Edward J. P. Zimmerman and Robert M. Weston, Sp. Assts. to Atty. Gen., for respondent.

Before BONE, Circuit Judge, and GOODMAN and MATHES, District Judges.


GOODMAN, District Judge.

The propriety of respondent Commissioner's determination that the petitioner received a partnership interest from his father by gift rather than by sale, is the issue tendered by this appeal from the Tax Court's decision, affirming respondent's determination.

Respondent assessed income tax deficiencies for the year 1943 against petitioner upon the theory that a partnership interest transferred by his father to petitioner was a gift...

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