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BRITT v. UNITED STATES

No. 27310.

431 F.2d 227 (1970)

T. M. BRITT and Jane Britt et al., Plaintiffs-Appellants, v. The UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

May 14, 1970.

Attorney(s) appearing for the Case

M. W. Wells, Jr., James A. Moreland, Orlando, Fla., for plaintiffs-appellants.

Edward F. Boardman, U. S. Atty., Tampa, Fla., Mitchell Rogovin, Johnnie M. Walters, Asst. Attys. Gen., Eugene P. Kopp, H. Stennis Little, Jr., Lee A. Jackson, Robert I. Waxman, Attys., Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant-appellee.

Before TUTTLE, WISDOM and BELL, Circuit Judges.

WISDOM, Circuit Judge:

This tax refund case involves the difficult application of the rule that income from property must be taxed to the individual who, in substance, is the owner of the property generating the income. Helvering v. Horst, 1940, 311 U.S. 112, 61 S.Ct. 144, 85 L.Ed. 75. Here, the taxpayers transferred the property in question to three corporations. The district court found that as a matter of law the level of business...

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