PALMER v. C. I. R.

No. 75-1102.

523 F.2d 1308 (1975)

Daniel D. and Agnes H. PALMER, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided September 30, 1975.


Attorney(s) appearing for the Case

Richard L. Braunstein, Dow, Lohnes & Albertson, Washington, D. C., for appellants.

William S. Estabrook, III, Atty., Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before GIBSON, Chief Judge, HENLEY, Circuit Judge, and VAN PELT, Senior District Judge.


GIBSON, Chief Judge.

Appellants, Daniel D. and Agnes H. Palmer (hereafter taxpayers), appeal from that part of a judgment of the United States Tax Court1 determining that they did not overpay income taxes for the year 1966 due to their alleged undervaluation of 238 shares of corporate stock of the Palmer College of Chiropractic donated to the Palmer College Foundation, a nonprofit corporation. In their 1966 joint return, taxpayers valued...

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