v3224-718
UNITED STATES
COURT OF APPEALS
FOR THE NINTH CIRCUIT
/TON F. LOUNSBURY and
IRRAINE M. LOUNSBURY,
Petitioners,
vs.
IMMISSIONER OF INTERNAL REVENUE,
Respondent.
PETITIONERS 1 ALTON F. LOUNSBURY
AND LORRAINE M LOUNSBURY
PETITION FOR REHEARING
Comes now the petitioners and respectfully petition this
morable Court for a rehearing in the above entitled matter for
le following reasons.
- It is respectfully submitted that the Court erred in
including that petitioner's $10,000 obligation to his former
.fe was to be met by a "lump sum payment" as distinguished from
eriodic payments" by which the wife shared in the husband's
icome, and by concluding that such payment was to be accomplished
r a "capital transfer". The evidence discloses, and the Tax
urt found, that the taxpayer had little if any assets or "capital"
I the date of divorce. He did not have $10,000. His obligation
pay the $10,000 could only be discharged out of his future
archive.org Volume Name: govuscourtsca9briefs3224
Volume: http://archive.org/stream/govuscourtsca9briefs3224
Document Link: http://archive.org/stream/govuscourtsca9briefs3224#page/n717/mode/1up
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