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UNITED STATES v. HALL

Nos. 6835, 6836.

307 F.2d 238 (1962)

UNITED STATES of America, Appellant, v. G. E. HALL and Christine B. Hall, Appellees. G. E. HALL and Christine B. Hall, Cross-Appellants, v. UNITED STATES of America, Cross-Appellee.

United States Court of Appeals Tenth Circuit.

July 27, 1962.

Attorney(s) appearing for the Case

Michael A. Mulroney, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and David O. Walter, Attys., Dept. of Justice, and B. Andrew Potter, U. S. Atty., on the brief), for appellant and cross-appellee.

Gus Rinehart, Oklahoma City, Okl. (Butler, Rinehart & Morrison, Oklahoma City, Okl., on the brief), for appellees and cross-appellants.

Before PHILLIPS, PICKETT and LEWIS, Circuit Judges.

LEWIS, Circuit Judge.

This case explores the personal income tax incidents that occur when a gambling debt is eliminated as between winner and loser by transfer from the loser to the winner of property having a value less than the amount of the debt. The general problem is further complicated by certain refinements appearing in the factual background. The suit arose in the United States District Court for the Western District of Oklahoma as a claim for refund of income...

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