Dean v. Caldwell & Co.

GORE, District Judge;

The collector of internal revenue is seeking, in this proceeding, to collect “Documentary Stamp Taxes” under title 8 of the Revenue Act of 1926 (26 USCA §§ 901. 902, and notes, 903 et seq.), and title 2, part 5, of the Revenue Act of 1928 (26 USCA § 901 and note, 902, 907a), assessed against the receivers of defendant, but covering transactions prior to receivership.

The assessment involves four classes of transactions: (1) Stock held by nominees for the use of defendants; (2) stock pledged to Bank of Tennessee by defendant as security for moneys borrowed; (3) where…