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SMITH v. COMMISSIONER OF INTERNAL REVENUE

No. 16513.

249 F.2d 218 (1957)

Jonnie Lou SMITH, Trustee, for Vickie Ann and Bobby Jean Smith, Transferees, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

November 8, 1957.

Attorney(s) appearing for the Case

James W. Arnold, Athens, Ga., for petitioner.

Charles K. Rice, Asst. Atty. Gen., John N. Stull, Acting Asst. Atty. Gen., Lee A. Jackson, Atty., Kenneth E. Levin, Atty., Herman T. Reiling, Acting Chief Counsel, Internal Revenue Service, Rollin H. Transue, Atty., Washington, D. C., Melva M. Graney, Atty., Department of Justice, Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and BORAH and CAMERON, Circuit Judges.

HUTCHESON, Chief Judge.

This appeal is from a judgment in Tax Court Docket No. 45854, one of three cases1 which were consolidated in the Tax Court, as involving transferee liability for income tax deficiencies and penalties assessed against V. Hugo Smith.

The Tax Court, in original and supplemental findings of fact2 and in opinions not officially reported,...

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