United States v. William D. Frazell and Martha T. Frazell

In support of the appellees’ petition for rehearing, briefs were filed by the ap-pellees and three amici curiae. The Commissioner responded to these briefs, and the four proponents of appellees’ position filed briefs in x-eply. After careful consideration of the arguments and authorities thus presented, we are persuaded that our original decision was a correct one.

Among the arguments presented in the appellees’ behalf on this petition is that the first two sentences of Treas. Reg. § 1.721-1 (b) (1) require a different result from that reached in our original decision. The pertinent language…