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SCHUSTER v. C. I. R.

Nos. 16774, 16825.

312 F.2d 311 (1962)

Melba SCHUSTER, formerly Melba D. Baker, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Melba SCHUSTER, formerly Melba D. Baker, Respondent. UNITED CALIFORNIA BANK, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. UNITED CALIFORNIA BANK, Respondent.

United States Court of Appeals Ninth Circuit.

November 26, 1962.

Attorney(s) appearing for the Case

Chickering & Gregory, Walter C. Fox, Jr., Burleigh Pattee, and Bruce M. Casey, Jr., San Francisco, Cal., for petitioner Melba Schuster.

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Meyer Rothwacks, A. F. Prescott, Sharon L. King, and Helen A. Buckley, Attys., Dept. of Justice, Washington, D. C., for Comr. of Internal Revenue.

Orrick, Dahlquist, Herrington & Sutcliffe, Orville A. Rohlf, Christopher M. Jenks, and William D. McKee, San Francisco, Cal., for United California Bank.

Before STEPHENS, JERTBERG and KOELSCH, Circuit Judges.

KOELSCH, Circuit Judge.

These are actions combined in this court to review two decisions of the Tax Court sustaining the Commissioner's determination that the petitioners are liable as transferees for unpaid estate taxes, pursuant to sections 827(b) and 900 of the Internal Revenue Code of 1939. (26 U.S.C. §§ 827(b), 900 (1952 ed.)).1 The Tax Court's opinions appear in

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