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BROWN v. COMMISSIONER OF INTERNAL REVENUE

No. 15584.

241 F.2d 827 (1957)

William Herbert BROWN and Mary F. Brown, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

March 8, 1957.

Attorney(s) appearing for the Case

Harry C. Avery and Kenneth F. Summers, St. Louis, Mo., for petitioners.

Carolyn R. Just, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., and Lee A. Jackson and Robert N. Anderson, Attys., Dept. of Justice, Washington, D. C., with her on the brief), for respondent.

Before JOHNSEN, VAN OOSTERHOUT and WHITTAKER, Circuit Judges.

JOHNSEN, Circuit Judge.

This is a petition by a taxpayer,1 to review a decision of the Tax Court, 25 T.C. 920.

The holding challenged is one that a payment of $3,105.24, made by the taxpayer to his two children in 1951, and a similar payment of $2600, made in 1952, were not entitled to be deducted by him from his gross income for those years, as interest, under 26 U.S.C.A. Int.Rev.Code of 1939, ...

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