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CULLERS v. COMMISSIONER OF INTERNAL REVENUE

Nos. 15501, 15502.

237 F.2d 611 (1956)

Frances M. CULLERS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. C. H. CULLERS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

October 18, 1956.

Attorney(s) appearing for the Case

Jess W. Van Ert, Kansas City, Mo. (John E. Park, Albert F. Hillix, and Gage, Hillix, Moore & Park, Kansas City, Mo., on the brief), for petitioners.

Kenneth E. Levin, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., and Robert N. Anderson and Hilbert P. Zarky, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before WOODROUGH, VOGEL and VAN OOSTERHOUT, Circuit Judges.

VAN OOSTERHOUT, Circuit Judge.

C. H. Cullers and Frances M. Cullers, husband and wife, hereinafter called taxpayers, have petitioned this court to review separate decisions of the Tax Court determining deficiencies in gift tax due from them for the year 1950. This court has jurisdiction. § 7482, Internal Revenue Code of 1954, 26 U.S.C.A.

Taxpayer C. H. Cullers, in 1950, by gift conveyed to his sons a 1500 acre farm near Trenton, Missouri, the gift also...

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