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COMMISSIONER OF INTERNAL REVENUE v. KREBS

Nos. 6319, 6320.

90 F.2d 880 (1937)

COMMISSIONER OF INTERNAL REVENUE v. KREBS (two cases).

Circuit Court of Appeals, Third Circuit.

June 4, 1937.

Attorney(s) appearing for the Case

James W. Morris, Asst. Atty. Gen., and Sewall Key and Berryman Green, Sp. Assts. to Atty. Gen., for petitioner.

Richard B. Barker, of Washington, D. C. (Ivins, Phillips, Graves & Barker, of Washington, D. C., of counsel), for respondent.

Before BUFFINGTON and THOMPSON, Circuit Judges, and MARIS, District Judge.

THOMPSON, Circuit Judge.

These are petitions for review of two decisions of the Board of Tax Appeals. In 1932 the taxpayer created three irrevocable trusts for the benefit of each of his three children. He transferred to each of those trusts without any valuable consideration, $5,000. In 1933, without any valuable consideration, he transferred to each of the trusts 50 shares of Dupont Company stock of the value of $4,712.50 and cash in the following amounts: $656...

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