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UNITED STATES v. COOK

Nos. 16132, 16145, 16133, 16146, 16134, 16147.

270 F.2d 725 (1959)

UNITED STATES of America, Appellant, v. Clement F. COOK, Appellee (two cases). UNITED STATES of America, Appellant, v. Wilfred L. COOK, Appellee (two cases). UNITED STATES of America, Appellant, v. Wilfred L. COOK and Patricia Cook, Appellees (two cases).

United States Court of Appeals Eighth Circuit.

October 8, 1959.

Attorney(s) appearing for the Case

Carolyn R. Just, Atty., Dept. of Justice, Washington, D. C. (Howard A. Heffron, Acting Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson and Louise Foster, Attys., Dept. of Justice, Washington, D. C., Fallon Kelly, U. S. Atty., and Hyam Segell, Asst. U. S. Atty., St. Paul, Minn., were with her on the brief), for appellant.

Joseph A. Maun, St. Paul, Minn. (Jerome B. Simon and Bundlie, Kelley & Maun, St. Paul, Minn., were with him on the brief), for appellees.

Before GARDNER, VOGEL and VAN OOSTERHOUT, Circuit Judges.

VOGEL, Circuit Judge.

These cases, consolidated for the purposes of trial, concern the proper tax treatment to be accorded income resulting from the sale by taxpayers of mink pelts derived from minks culled from their breeding herd. No issues of fact are presented. It is conceded that the business of the taxpayers during the years in question consisted of raising minks for the purpose of selling mink pelts; that this business required the development and maintenance...

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