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LAZARUS v. C. I. R.

Nos. 73-2737 to 73-2739.

513 F.2d 824 (1975)

Simon M. LAZARUS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Mina LAZARUS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Simon M. and Mina LAZARUS, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

April 2, 1975.

Attorney(s) appearing for the Case

Ben Margolis (argued), Los Angeles, Cal., for petitioners-appellants.

Donald Olson (argued), I.R.S., Washington, D. C., for respondent-appellee.

Before CHAMBERS and KOELSCH, Circuit Judges, and JAMESON, District Judge.

OPINION

JAMESON, District Judge:

Three actions are consolidated on this appeal. In Cause No. 73-2739, the petitioners, Simon and Mina Lazarus, husband and wife, seek review of a judgment of the United States Tax Court sustaining an income tax deficiency assessment in connection with an alleged "private annuity" transaction in which petitioners transferred stock to an irrevocable trust in return for a joint and survivor "annuity". In Causes Nos. 73-2737 and...

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