Olga K. AUDANO and B. Randol Hardwick, Plaintiffs-Appellees,
v.
UNITED STATES of America, Defendant-Appellant.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
June 26, 1970.
June 26, 1970.
Attorney(s) appearing for the Case
Gene A. Castleberry, U. S. Dept. of Justice, Tax Div., Fort Worth, Tex., Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Atty., Tax Div. Dept. of Justice, Washington, D. C., Eldon B. Mahon, U. S. Atty., William L. Johnson, Jr., Asst. U. S. Atty., Fort Worth, Tex., William A. Friedlander, Stanley I. Ruby, Attys., Tax Div., U. S. Dept. of Justice, Washington, D. C., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., for appellant.
Roger Norman, Fort Worth, Tex., for appellees, Shannon, Gracey, Ratliff & Miller, Fort Worth, Tex., of counsel.
Before WISDOM, AINSWORTH and CLARK, Circuit Judges.
United States Court of Appeals, Fifth Circuit.
AINSWORTH, Circuit Judge:
In this case we are required to determine the proper tax treatment of certain payments made by a medical partnership of which taxpayer1 was a member to three trusts set up by taxpayer for the benefit of his children. These payments were made as rent for the use of medical, surgical, and other equipment used in the partnership business, which equipment taxpayer had transferred to the trusts and which the partnership...
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