Sewell's Estate v. Commissioner

McCORD, Circuit Judge.

The three Sewell Brothers, who owned virtually all the stock in the Sewell Manufacturing Company, a corporation engaged in the manufacture of men’s and boys’ clothing, entered into an agreement and made over to their wives by way of alleged gifts, certain stock in the corporation.

This appeal involves income tax liability of the estate of R. A. Sewell, deceased, for the calendar years 1934, 1935, 1936 and 1937. The questions presented are: (1) Whether a gift of 1000 shares of corporate stock in the Sewell Manufacturing Company in 1934, and 300 additional shares in July…