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CONRAN v. UNITED STATES

No. S 70 C 23.

322 F.Supp. 1055 (1971)

LaVonna CONRAN, Mary Susan Conran McLaughlin, Sally Ann Conran Maxwell, James E. Reeves, and R. L. Saalwaechter, Co-Executors of the Estate of James V. Conran, Deceased, and LaVonna Conran, widow of James V. Conran, Deceased, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Missouri, Southeastern Division.

February 4, 1971.

Attorney(s) appearing for the Case

James E. Reeves, Ward & Reeves, Caruthersville, Mo., for plaintiffs.

Daniel Bartlett, Jr., U. S. Atty., Harold E. Zahner, Asst. U. S. Atty., St. Louis, Mo., Johnnie M. Walters, Asst. Atty. Gen., Harold S. Larsen and Michael C. Durney, Attys., Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM

MEREDITH, Chief Judge.

This is a suit for the recovery of federal income taxes alleged to have been overpaid by James V. Conran (deceased) and LaVonna Conran for the year 1966 in the amount of $11,526.38, plus statutory interest. At issue in this proceeding is the question of whether the $17,458.36 gain realized from the severance damages is to be recognized as taxable income or whether it qualifies for deferral of recognition, pursuant to 26...

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