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KERR v. C. I. R.

No. 18371.

326 F.2d 225 (1964)

Thomas KERR and Barbara Kerr, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

January 3, 1964.

Attorney(s) appearing for the Case

Black & Apicella, John P. Apicella and Guy J. Rappleyea, Portland, Or., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney, Ralph A. Muoio, and Meyer Rothwacks, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before CHAMBERS and BARNES, Circuit Judges, and BEEKS, District Judge.

BARNES, Circuit Judge:

This is a petition for review of a decision of the Tax Court in favor of the Commissioner. 38 T.C. 723. The Tax Court had jurisdiction of the cause under Section 6213.1 This court has jurisdiction of this petition pursuant to Section 7482.

The taxpayer, Thomas Kerr,2 owned all of the stock of two corporations. On October 24, 1955, he transferred...

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