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DRYBROUGH v. C.I.R.

No. 16525.

376 F.2d 350 (1967)

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

United States Court of Appeals Sixth Circuit.

March 30, 1967.

Attorney(s) appearing for the Case

Rucker Todd, Louisville, Ky., for petitioners, Brown, Ardery, Todd & Dudley, Louisville, Ky., of counsel.

Robert A. Bernstein, Tax Division, Dept. of Justice, Washington, D. C., for respondent, John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Herbert Grossman, Attys., Dept. of Justice, Washington, D. C., on the brief.

Before O'SULLIVAN and CELEBREZZE, Circuit Judges, and McALLISTER, Senior Circuit Judge.

O'SULLIVAN, Circuit Judge.

This matter is before us on the petition of taxpayers, F. W. Drybrough and the executor of the estate of his deceased wife, Citizens Fidelity Bank & Trust Company, to review a decision of the Tax Court of the United States, reported as Drybrough v. Commissioner, 42 T.C. 1029 (1964). Conduct by F. W. Drybrough is primarily involved and we shall refer only to him as the taxpayer or petitioner. The issues...

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