GUNNISON v. C. I. R.

No. 71-1261.

461 F.2d 496 (1972)

Richard N. GUNNISON and Vivian E. Gunnison, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided May 2, 1972.


Attorney(s) appearing for the Case

Martin J. Lillig, John Blyer Callahan, Chicago, Ill., for petitioners-appellants.

Johnnie M. Walters, Asst. Atty. Gen., William L. Goldman, Meyer Rothwacks, Richard W. Perkins, Ann E. Belanger, Attys., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before DUFFY and KNOCH, Senior Circuit Judges, and GRANT, District Judge.


KNOCH, Senior Circuit Judge.

The facts in this case are largely stipulated and may be briefly stated as follows. The late Walter L. Gunnison, father of petitioner-appellant Richard N. Gunnison, was employed by Enterprise Railway Equipment Company. Vivian E. Gunnison is a party to this cause only because she and her husband Richard filed a joint return. References hereinafter to "petitioner" mean Richard N. Gunnison.

In 1945 and in 1951, respectively, Enterprise...

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