HERINGER v. COMMISSIONER OF INTERNAL REVENUE

No. 14574.

235 F.2d 149 (1956)

Stephen F. HERINGER, Mabel H. Heringer, John F. Heringer, and Alta G. Heringer, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

Rehearing Denied July 9, 1956.


Attorney(s) appearing for the Case

R. E. H. Julian, San Francisco, Cal., for petitioners.

H. Brian Holland, Asst. Atty. Gen., Robert N. Anderson, A. F. Prescott, Myer Rothwacks, John Kelley, Jr., Sp. Assts. to the Atty. Gen., for respondent.

Before ORR and CHAMBERS, Circuit Judges, and MATHES, District Judge.


ORR, Circuit Judge.

John F. and Stephen Heringer and their wives Mabel H. and Alta G. respectively, and hereafter petitioners, appear from the record to be thrifty people who have conducted successful farming operations during the years. Each couple has several children. On or about January 5, 1947 petitioners concluded that the major portion of their property should be transferred to a corporation, whose stock was to be distributed between parents and children. Pursuant...

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