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COOPER'S ESTATE v. C. I. R.

Nos. 8295, 8327, 8328.

291 F.2d 831 (1961)

ESTATE of William P. COOPER, Deceased, Daisy H. Cooper, Executrix, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. PERPETUAL BUILDING AND LOAN ASSOCIATION OF COLUMBIA, Petitioner and Cross-Respondent, v. COMMISSIONER OF INTERNAL REVENUE, Respondent and Cross-Petitioner. COOPER AGENCY, Petitioner and Cross-Respondent, v. COMMISSIONER OF INTERNAL REVENUE, Respondent and Cross-Petitioner.

United States Court of Appeals Fourth Circuit.

Decided June 19, 1961.

Attorney(s) appearing for the Case

E. W. Mullins and Charles F. Cooper, Columbia, S. C. (Nelson, Mullins, Grier & Scarborough, Columbia, S. C., on the brief), for petitioner and petitioner and cross-respondent.

Karl Schmeidler, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Meyer Rothwacks, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent and respondent and cross-petitioner.

Before SOPER, HAYNSWORTH and BOREMAN, Circuit Judges.

PER CURIAM.

These cases relate to the income tax liability of certain corporations controlled by three brothers — Frank B. Cooper, Charles F. Cooper, and James D. Cooper — whose tax liabilities from activities in the development of real estate and in other fields were considered by us in Biltmore Homes, Inc. et al. v. Commissioner, 4 Cir., 1961, 288 F.2d 336. In that case we affirmed the decision of the Tax Court, which...

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