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BOWDEN v. COMMISSIONER OF INTERNAL REVENUE

No. 15922.

234 F.2d 937 (1956)

James Richard BOWDEN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied July 28, 1956.

Attorney(s) appearing for the Case

J. Richard Bowden, in pro. per.

Morton K. Rothschild, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Acting Asst. Atty. Gen., Lee A. Jackson, Atty., John Potts Barnes, Chief Counsel, Int. Rev. Ser., Charles E. Lowery, Sp. Atty., Hilbert P. Zarky, Atty., L. W. Post, Atty., Dept. of Justice, Washington, D. C., for respondent.

Before TUTTLE, CAMERON and JONES, Circuit Judges.

JONES, Circuit Judge.

The petitioner, James Richard Bowden, herein called the taxpayer, and his two sisters, in 1950, created an irrevocable trust by a written agreement with Trust Company of Georgia. The donors transferred to the trustee assets of a value of slightly more than $300,000. The contribution of the taxpayer to the trust res was of the value of $100,392.48. The taxpayer was then fifty-two years of age. The trust agreement provided for payment of $400.00...

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