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STARRELS v. C. I. R.

No. 17358.

304 F.2d 574 (1962)

Maurie STARRELS and Doris W. Starrels, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

May 25, 1962.

Attorney(s) appearing for the Case

Kenny, Morris, & Ibanez, Robert S. Morris, and Robert W. Kenny, Los Angeles, Cal., for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harold M. Seidel, and William Friedlanders, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before BARNES, JERTBERG and BROWNING, Circuit Judges.

BROWNING, Circuit Judge.

The Tax Court decision before us for review was founded upon a stipulation disclosing the following facts: Doris W. Starrels is the daughter of the late Commander Frank W. Wead. Loew's, Inc. wished to produce a motion picture about naval aviation. Loew's agreed to pay Mrs. Starrels certain sums of money in return for her consent to the portrayal of her father, herself, and other members of the family in the proposed movie. Loew's subsequently...

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