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FULLER v. C. I. R.

No. 14859.

313 F.2d 73 (1963)

Lucille FULLER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent (two cases). ESTATE of Charles WILLIS, Deceased, Mrs. Lucille Fuller, Executrix, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

February 5, 1963.

Attorney(s) appearing for the Case

John Kennedy Lynch, Cleveland, Ohio, for petitioners.

Alan D. Pekelner, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, I. Henry Kutz, Attys., Dept. of Justice, Washington, D. C., on brief), for respondent.

Before MILLER and WEICK, Circuit Judges, and WILLIAM E. MILLER, District Judge.

WEICK, Circuit Judge.

This review involves the validity of determinations of income tax deficiencies and fraud penalties made by the Commissioner against the estate of Charles Willis, deceased, for the tax years 1949 to 1954 inclusive and the liability of his sister, Lucille Fuller, as transferee of his assets.

The case was submitted to the Tax Court on stipulations, testimony of witnesses, exhibits and briefs. The...

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