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COMMISSIONER OF INTERNAL REV. v. GODLEY'S ESTATE

No. 11202.

213 F.2d 529 (1954)

COMMISSIONER OF INTERNAL REVENUE v. GODLEY'S ESTATE.

United States Court of Appeals, Third Circuit.

Decided May 28, 1954.

Attorney(s) appearing for the Case

Melva M. Graney, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Lee A. Jackson, Sp. Assts. to the Atty. Gen. on the brief), for petitioner.

Allen S. Hubbard, New York City (Hughes, Hubbard, Blair & Reed, New York City, John Westbrook Fager, Norman Thomas Gilroy, Jr., New York City, on the brief), for respondent.

Before MARIS, KALODNER, and STALEY, Circuit Judges.

STALEY, Circuit Judge.

The Commissioner petitions for review of a decision of the Tax Court. 19 T.C. 1082 (1953). The facts were stipulated and were found accordingly. We will attempt to state them generally so that this opinion does not become a welter of figures.

Respondents' decedent held stock of the Southern Natural Gas Company. In 1947 she and the other shareholders of the gas company received a distribution partly in...

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