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REINECKE v. COMMISSIONER OF INTERNAL REVENUE

No. 15049.

220 F.2d 406 (1955)

Mignon REINECKE, Transferee, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eighth Circuit.

March 24, 1955.

Attorney(s) appearing for the Case

Henry C. Lowenhaupt, St. Louis, Mo. (William R. MacGreevy and Lowenhaupt, Mattingly, Chasnoff & Stolar, St. Louis, Mo., on the brief), for petitioner.

Karl Schmeidler, Sp. Asst. to Atty. Gen. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky and Louise Foster, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before SANBORN, WOODROUGH and JOHNSEN, Circuit Judges.

JOHNSEN, Circuit Judge.

Carl J. Reinecke owed income-tax deficiencies for the years 1945, 1946 and 1947, amounting to $10,177.74. In January, 1948, he married the petitioner here, Mignon Reinecke. Thereafter, he transferred or assigned to her an insurance annuity contract, issued to him by Phoenix Mutual Life Insurance Co., dated March 25, 1937, and having at the time of the assignment or transfer a cash surrender value exceeding the amount of his income-tax deficiencies...

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