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CRANE v. C. I. R.

No. 6779.

368 F.2d 800 (1966)

Winthrop M. CRANE, III, et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals First Circuit.

Decided November 25, 1966.

Attorney(s) appearing for the Case

Jesse R. Fillman, Boston, Mass., with whom James M. Keith, Pittsfield, Mass., and Choate, Hall & Stewart, Boston, Mass., were on brief, for petitioners.

Stuart A. Smith, Atty., Department of Justice, with whom Mitchell Rogovin, Asst. Atty. Gen., and Lee A. Jackson and Gilbert E. Andrews, Attys., Department of Justice, were on brief, for respondent.

Before ALDRICH, Chief Judge, McENTEE and COFFIN, Circuit Judges.

ALDRICH, Chief Judge.

These are consolidated petitions to review decisions of the Tax Court upholding the Commissioner's imposition of deficiencies. Basic to the case is an undertaking which the court found to be a trust, and since petitioners so claim, we will assume found correctly. The exact terms of this trust are quoted in the court's opinion, Winthrop M. Crane, III, 1966, 45 T.C. 397, together with a detailed stipulation, neither...

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