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PHIPPS v. UNITED STATES

No. 109-72.

515 F.2d 1099 (1975)

Ogden PHIPPS and Lillian B. Phipps v. The UNITED STATES.

United States Court of Claims.

April 16, 1975.

Attorney(s) appearing for the Case

Kenneth L. MacCardle, New York City, for plaintiff. Irving H. Bull, New York City, attorney of record. Dunnington, Bartholow & Miller, New York City, of counsel.

Scott P. Crampton, Asst. Atty. Gen., for defendant. Allan C. Lewis, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and DAVIS, SKELTON, NICHOLS, KASHIWA, KUNZIG and BENNETT, Judges.

ON PLAINTIFFS' MOTION AND DEFENDANT'S CROSS MOTION FOR SUMMARY JUDGMENT

NICHOLS, Judge:

This suit arises out of disputes over the tax consequences of Ogden Phipps' partnership agreements in Smith, Barney & Co., for 1959 and for 1960-63. The business was underwriting the sale of securities and acting as a broker and dealer in securities. Lillian B. Phipps is a party solely because she signed joint tax returns...

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