May 19, 1930
JULIA ANDREWS BRUCE, PETITIONER,
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
Appeal from the United States Board of Tax Appeals.
Before MANTON, SWAN, and AUGUSTUS N. HAND, Circuit Judges.
MANTON, Circuit Judge.
This petitioner owned 350 shares of stock of the Andrews & Hitchcock Iron Company, which she owned prior to March 1, 1913, and sold on March 11, 1916, under the circumstances and terms referred to in the case of Logan v. Commissioner (C.C.A.) 42 F.2d 193, decided this day. She also inherited 550/4000 interest from her mother's estate. The income in question was moneys received during two years, 1918 and 1919, as payment made pursuant to the contract obligation of the Youngstown Sheet & Tube Company to this petitioner. The same contract is involved. For the reasons there stated, it follows that the order of the Board determining these moneys in part to be income and taxable was erroneous, and the order must be reversed.
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