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VICTORSON v. C. I. R.

Nos. 85, 86, Docket 28319, 28320.

326 F.2d 264 (1964)

Edward C. VICTORSON and Anne Victorson, Graham, Ross & Co., Inc., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Edward C. VICTORSON and Anne Victorson, Graham, Ross & Co., Inc., Respondents.

United States Court of Appeals Second Circuit.

Decided January 15, 1964.

Attorney(s) appearing for the Case

Martin M. Lore, New York City, for taxpayers.

Edward L. Rogers, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, and Melva M. Graney, Washington, D. C., on the brief), for Commissioner.

Before CLARK, SMITH and HAYS, Circuit Judges.

HAYS, Circuit Judge:

Edward C. Victorson, Anne Victorson, and Graham, Ross & Company, Inc., seek review of decisions of the Tax Court of the United States upholding the Commissioner's determination that the taxpayers realized income when they exercised the right to purchase stock in Glamur Products, Inc., a right which they secured as partial compensation for their services in underwriting a public issue of Glamur Products stock. To safeguard the revenue the Commissioner...

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