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PETERSON v. COMMISSIONER OF INTERNAL REVENUE

No. 20515.

380 F.2d 1 (1967)

William S. PETERSON and Betty M. Peterson, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

June 5, 1967.

Attorney(s) appearing for the Case

Milton O. Wordal, Dale Forbes, Melvyn M. Ryan, Church, Harris, Johnson & Williams, Great Falls, Mont., for appellants.

Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson, Harold C. Wildenfeld, Edward Heilbronner, C. Moxley Featherston, Attys., Tax Div., Dept. of Justice, Washington, D.C., Mitchell Rogovin, Chief Counsel, I.R.S., Washington, D.C., for appellee.

Before CHAMBERS, HAMLIN and KOELSCH, Circuit Judges.

CHAMBERS, Circuit Judge:

William Peterson is a successful promoter of cemeteries. Like most of us, he doesn't want to pay any higher income taxes than necessary.

At Kalispell, Montana, in 1955, he acquired initially ten acres of land for $2500. Then he and Mrs. Peterson set up a commercial corporation called Glacier Memorial Gardens of Kalispell, Inc. The two Petersons received the only stock issued by the company for...

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