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SCHWARZ v. UNITED STATES

No. 6254.

191 F.2d 618 (1951)

SCHWARZ et al. v. UNITED STATES.

United States Court of Appeals Fourth Circuit.

Decided September 10, 1951.

Attorney(s) appearing for the Case

Samuel Bogorad, Washington, D. C. (Wilson R. Toula, Baltimore, Md., on the brief), for appellants.

Virginia H. Adams, Sp. Asst. to Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack and Lee A. Jackson, Sp. Asst. to Atty. Gen., Bernard J. Flynn, U. S. Atty. and Frederick J. Green Jr., Asst. U. S. Atty., Baltimore, Md., on the brief), for appellee.

Before PARKER, Chief Judge, and SOPER and DOBIE, Circuit Judges.

PARKER, Chief Judge.

This is an appeal in an action to obtain a judgment for a deficiency in income taxes, with penalties and interest, and to subject to the payment thereof two annuity contracts of the taxpayer and a half interest in a tract of land which had been deeded to him and his wife as tenants by the entireties. There was judgment in favor of the United States for $96,766.55, the amount of the taxes with penalties and interest; and the annuity contracts and...

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