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ESTATE HEDRICK v. COMMISSIONER OF INTERNAL REVENUE

No. 26292.

457 F.2d 501 (1972)

ESTATE of Walburga HEDRICK, Deceased, aka Walburga Oesterreich, Ray Bert Hedrick, Executor, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied June 28, 1972.

Attorney(s) appearing for the Case

Charles I. Rosin (argued), Los Angeles, Cal., for petitioner.

Michael Paup (argued), William Massar, Meyer Rothwacks, Johnnie Walters, Asst. Atty. Gen., K. Martin Worthy, Washington, D. C., for respondent.

Before CHAMBERS and JERTBERG, Circuit Judges, and CROCKER, District Judge.

PER CURIAM:

The decision of the Tax Court, pursuant to our Estate of Hedrick v. Commissioner of Internal Revenue, 406 F.2d 587 (9th Cir., 1969), is affirmed.

On remand, the Tax Court, in reconstructing the transaction, adopted as to the Hedrick Estate a rate of 7%. This resulted in establishing an original sale value, as reconstructed of an amount about twice the actual cash value of the property at the time of sale.

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