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BROWN v. UNITED STATES

No. 35-65.

396 F.2d 459 (1968)

Sumner E. and Barbara P. BROWN v. The UNITED STATES.

United States Court of Claims.

June 14, 1968.

Attorney(s) appearing for the Case

John M. Doukas, Boston, Mass., attorney of record, for plaintiffs.

Michael I. Sanders, Washington, D. C., with whom was Asst. Atty. Gen. Mitchell Rogovin, for defendant, Philip R. Miller, Washington, D. C., of counsel.

Before COWEN, Chief Judge, LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON, and NICHOLS, Judges.

OPINION

LARAMORE, Judge.

This case involves another aspect of the income tax consequences which have burgeoned from the transactions devised by Livingstone & Company (hereinafter referred to as Livingstone). The record before us is a stipulation of facts which, succinctly stated, discloses a typical "Livingstone" transaction.

Plaintiffs, Sumner E. and Barbara P. Brown, husband and wife, filed joint Federal personal income tax returns for the...

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