STEPHENS, INC. v. UNITED STATES

Nos. 71-1571 and 71-1586.

464 F.2d 53 (1972)

STEPHENS, INC., Appellee and Cross-Appellant, v. UNITED STATES of America, Appellant and Cross-Appellee.

United States Court of Appeals, Eighth Circuit.

Decided July 10, 1972.

Rehearing and Rehearing Denied August 22, 1972.


Attorney(s) appearing for the Case

Herschel H. Friday, Jr., and William H. Bowen, Little Rock, Ark., for Stephens Inc.

William L. Goldman, Atty., Tax Div., Dept. of Justice, Washington, D. C., for United States.

Before LAY, BRIGHT and ROSS, Circuit Judges.


Rehearing and Rehearing En Banc Denied August 22, 1972.

LAY, Circuit Judge.

This is an appeal arising out of a judgment in the sum of $576,424.63 in favor of the taxpayer in a suit for refund of taxes. The focal issue turns on whether the claim of the taxpayer, Stephens, Incorporated, that it was acting as a securities dealer when handling the stocks of five separate corporations, is correct. The district court held that as to four of these corporate stocks...

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