CARLTON v. COMMISSIONER OF INTERNAL REVENUE

No. 13373.

190 F.2d 183 (1951)

CARLTON v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

June 25, 1951.


Attorney(s) appearing for the Case

Doyle E. Carlton, Michel G. Emmanuel, Tampa, Fla., for petitioner.

Louise Foster, Ellis N. Slack, Robert N. Anderson, Morton K. Rothschild, Special Assts. to Atty. Gen., Theron L. Caudle, Asst. Atty. Gen., Charles Oliphant, Chief Counsel, Charles E. Lowery, Special Attorney, Bureau of Internal Revenue, Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and SIBLEY and STRUM, Circuit Judge.


JOSEPH C. HUTCHESON, Chief Judge.

Appealing from a decision of the Tax Court finding and declaring a deficiency in gift taxes for 1944, in respect of gifts in trust to petitioner's wife for their children, petitioner attacks the decision as erroneous in two particulars.

One of these is the rejection of petitioner's claim that twenty percent of the property conveyed in trust belonged to his wife and should not have...

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