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HARWELL v. COMMISSIONER OF INTERNAL REVENUE

No. 3663.

170 F.2d 517 (1948)

HARWELL et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Tenth Circuit.

November 1, 1948.

Attorney(s) appearing for the Case

Philip L. Kelton, of Dallas, Tex. (Strasburger, Price, Holland, Kelton & Miller, of Dallas, Tex., on the brief), for petitioners.

Wm. B. Waldo, Sp. Asst. to Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., and George A. Stinson and Harry Marselli, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before PHILLIPS, Chief Judge, and BRATTON and MURRAH, Circuit Judges.

PHILLIPS, Chief Judge.

This is a petition to review a decision of the Tax Court. On September 30, 1937, E. P. Harwell, who owned all of the outstanding stock of the Trinity Farm Securities Company, a corporation, exchanged all of such stock for the assets of the corporation. A part of the assets thus acquired was approximately 4500 acres of land situate in Dallas County Levee Improvement District No. 5.1 On the date of the exchange, the...

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