M. HAMPTON MAGRUDER, COLLECTOR OF INTERNAL REVENUE FOR DISTRICT OF MARYLAND, APPELLANT,
v.
FREDERICK M. SUPPLEE, AND ELIZABETH G. SUPPLEE, HIS WIFE, APPELLEES
M. HAMPTON MAGRUDER, COLLECTOR OF INTERNAL REVENUE FOR DISTRICT OF MARYLAND, APPELLANT,
FREDERICK M. SUPPLEE, AND ELIZABETH G. SUPPLEE, HIS WIFE, APPELLEES
123 F.2d 399
United States Court of Appeals for the Fourth Circuit (1941)
Opinion of the Court
PER CURIAM.
The majority of the court are of opinion that the judgment, 36 F.Supp. 722, appealed from should be affirmed on the opinion of the court below and on the authority of the decision of this court in Commissioner v. Rust’s Estate, 4 Cir., 116 F. 2d 636. Judge Parker dissents on the ground that the taxes paid, being a lien on the land and a personal liability of the vendor at the time of the conveyance to the taxpayer, were not deductible by the latter from income, for the reasons set forth in the dissenting opinion in the Rust case.
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Commissioner of Internal Revenue v. Rust's Estate, 116 F.2d 636 (4th Cir. 1940)