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HYDE v. C. I. R.

No. 218, Docket 27145.

301 F.2d 279 (1962)

Katharine T. HYDE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided April 5, 1962.

Attorney(s) appearing for the Case

George A. Burrell, New York City (Wolf & Burrell, New York City, on the brief), for petitioner.

Giora Ben-Horin, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Joseph Kovner, Attys., Dept. of Justice, Washington, D. C.), for respondent.

Before MOORE, FRIENDLY and MARSHALL, Circuit Judges.

LEONARD P. MOORE, Circuit Judge.

Katharine T. Hyde brings this petition to review a decision of the Tax Court which sustained the Commissioner's determination of a deficiency in her income tax for the years 1954 and 1955. The alleged deficiency resulted from the failure of petitioner to include in her income for these years the amount of insurance premiums paid by her husband on certain life insurance policies which had been irrevocably assigned by him to her, pursuant...

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