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LIVERNOIS TRUST v. C. I. R.

Nos. 20141-20143.

433 F.2d 879 (1970)

Theodore B. LIVERNOIS TRUST of May 2, 1958, Theodore B. Livernois, Jr., and Albert L. Grigsby, Jr., Trustees, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Alma G. LIVERNOIS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Alma G. LIVERNOIS, Petitioner-Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Cross-Appellant.

United States Court of Appeals, Sixth Circuit.

October 12, 1970.

Attorney(s) appearing for the Case

Michael J. Mehr, Detroit, Mich., for appellants and cross-appellee; Jerry D. Luptak, Evans, Boyer, Luptak & Briggs, Detroit, Mich., on brief.

Issie L. Jenkins, Atty., Dept. of Justice, Washington, D. C., for appellee and cross-appellant; Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, William A. Friedlander, Attys., Dept. of Justice, Washington, D. C., on brief.

Before EDWARDS and McCREE, Circuit Judges, and KALBFLEISCH, District Judge.

EDWARDS, Circuit Judge.

These cases present a complicated set of facts and at least one appellate issue of some importance in federal tax law. They were heard by the Tax Court which found for the Commissioner in an opinion containing a detailed statement of the cases and findings of fact and conclusions of law. (T.C. Memo. 1969-111). We shall rely upon the Tax Court opinion for the details of the case and recite only those facts...

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