John C. W. DIX and Caroline W. Dix, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
George E. DIX, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fourth Circuit.https://leagle.com/images/logo.png
Argued November 9, 1967.
Decided April 2, 1968.
Attorney(s) appearing for the Case
Richard A. Bishop, Washington, D. C., for petitioners.
Stephen H. Paley, Attorney, Department of Justice (Richard C. Pugh, Acting Asst. Atty. Gen., Meyer Rothwacks and Harold C. Wilkenfeld, Attorneys, Department of Justice, on brief), for respondent.
Before HAYNSWORTH, Chief Judge, MARVIN JONES, Senior Judge, U. S. Court of Claims, and BOREMAN, Circuit Judge.
United States Court of Appeals Fourth Circuit.
MARVIN JONES, Senior Judge:
Taxpayers,1 private individuals, entered a written arm's-length contract with their 79-year-old mother, dated June 20, 1960, under which they received corporate stocks worth $162,689.75 in exchange for their promise to pay her $22,452.00 per year in semiannual installments for the remainder of her life. Immediately following this transaction, and before any payment was made to their mother, taxpayers sold a...
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