DOWNS v. COMMISSIONER OF INTERNAL REVENUE.

Nos. 11578, 11593.

166 F.2d 504 (1948)

DOWNS v. COMMISSIONER OF INTERNAL REVENUE. HOOFNEL v. SAME.

Circuit Court of Appeals, Ninth Circuit.

Writ of Certiorari Denied June 1, 1948.


Attorney(s) appearing for the Case

Robert A. Waring, of Los Angeles, Cal., for petitioners.

Theron L. Caudle, Asst. Atty. Gen., Sewall Key, Berryman Green and Newton Fox, Sp. Assts. to the Atty. Gen., for respondent.

Before MATHEWS, STEPHENS and ORR, Circuit Judges.


STEPHENS, Circuit Judge.

The cases of Downs v. Commissioner, No. 11,578, and Hoofnel v. Commissioner, No. 11,593, here from the Tax Court on review, call for decision, mainly, upon the same basic principles. By general agreement they were tried together to the Tax Court, and were argued together here, although the cases are separately briefed. We shall dispose of the two cases in one opinion.

The Commissioner of Internal Revenue found Downs delinquent in his...

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