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DRYBROUGH v. C. I. R.

No. 17355.

384 F.2d 715 (1967)

F. W. DRYBROUGH et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

October 31, 1967.

Attorney(s) appearing for the Case

Rucker Todd, Louisville, Ky. (John T. Bondurant, Louisville, Ky., on the brief; Brown, Ardery, Todd & Dudley, Louisville, Ky., of counsel), for petitioners.

William A. Friedlander, Dept. of Justice, Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before O'SULLIVAN and PHILLIPS, Circuit Judges, and CECIL, Senior Circuit Judge.

PER CURIAM.

This case is before the Court on petition of F. W. Drybrough and the Estate of Marion S. Drybrough, Deceased, to review a decision of the Tax Court. Deficiencies in the joint tax returns of F. W. Drybrough and his wife Marion, for the years 1959 and 1960, are involved. On March 2, 1959, F. W. Drybrough, whom we will refer to as the Taxpayer, sold the assets of a proprietorship known as "United Mercantile Agencies" to United Mercantile Agencies, Inc.

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