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STATE OF TEXAS v. UNITED STATES

Civ. A. No. 1526.

263 F.Supp. 1 (1967)

The STATE OF TEXAS and the Board of Regents of the University of Texas, Trustees of the Hogg Foundation, W. C. Hogg Memorial Fund, Plaintiffs, v. The UNITED STATES of America, Defendant.

United States District Court W. D. Texas, Austin Division.

January 18, 1967.

Attorney(s) appearing for the Case

Waggoner Carr, Atty. Gen. of Texas, Austin, Tex., B. L. Bird, Fort Worth, Tex., Burnell Waldrep, Austin, Tex., for plaintiffs.

Mitchell Rogovin, Asst. Atty. Gen., Dept. of Justice, Washington, D. C., Robert L. Waters, Atty., Tax Div., Dept. of Justice, Fort Worth, Tex., for defendant.

MEMORANDUM OPINION

ROBERTS, District Judge.

This is a suit for refund of income taxes paid, brought by The State of Texas and the Board of Regents of the University of Texas on behalf of the Hogg Foundation—W. C. Hogg Memorial Fund.

I.

In the 1920's, Will (W. C.) Hogg, Mike Hogg, Tom Hogg and Ima Hogg, owners of various downtown and urban Houston and San Antonio properties, placed ten fee...

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