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BISHOP v. C. I. R.

No. 15894.

342 F.2d 757 (1965)

Constance M. BISHOP, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

March 24, 1965.

Attorney(s) appearing for the Case

Charles E. Pierson and Kenneth G. Humer, Akron, Ohio, for petitioner.

James F. Flug, Dept. of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Edward B. Greensfelder, Jr., Attys., Dept. of Justice, Washington, D. C., on the brief, for respondent.

Before MILLER, CECIL and EDWARDS, Circuit Judges.

SHACKELFORD MILLER, Jr., Circuit Judge.

The taxpayer, Constance M. Bishop, a widow of more than 65 years of age, borrowed in 1954 $159,000.00 from The Society for Savings, Cleveland, Ohio, using as collateral securities which were not tax-exempt obligations under Section 265(2), Internal Revenue Code. The proceeds of this loan were used to purchase stock and debentures of a corporation, Producing Properties, Inc., which,...

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