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DIXON v. UNITED STATES

No. 451, Docket 28752.

333 F.2d 1016 (1964)

W. Palmer DIXON et al., Plaintiffs-Appellants, Helen J. Gernon and Helene G. Hirson, as Executrices of the Last Will and Testament of Frank E. Gernon, Deceased, Helen J. Gernon, Plaintiffs, v. The UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Second Circuit.

Decided June 19, 1964.

Attorney(s) appearing for the Case

Bernard E. Brandes, of Stroock & Stroock & Lavan, New York City (Sanford Saideman, New York City, of counsel), for plaintiffs-appellants.

Robert Arum, Asst. U. S. Atty., for Southern District of New York, New York City (Robert M. Morgenthau, U. S. Atty., of counsel), for defendant-appellee.

Before MOORE, SMITH and KAUFMAN, Circuit Judges.

KAUFMAN, Circuit Judge.

The sole question presented by this appeal is whether profits attributable to original issue discount on "commercial paper," defined as short-term, non-interest-bearing commercial obligations, are taxable at ordinary income or capital gains rates under the Internal Revenue Code of 1939.1

The relevant facts in this case are free from dispute. Thus, the plaintiffs' amended complaint reveals that during the...

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