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NOWLAND v. COMMISSIONER OF INTERNAL REVENUE

No. 7369.

244 F.2d 450 (1957)

Robert L. NOWLAND and Mary C. Nowland. The North Beach Amusement Company, Inc., Charles E. Nelson and Virginia M. Nelson, his wife, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided May 15, 1957.

Attorney(s) appearing for the Case

Eldridge Hood Young, Baltimore, Md., for petitioners.

Melvin L. Lebow, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., and Harry Baum, Atty., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before SOPER and SOBELOFF, Circuit Judges, and HUTCHESON, District Judge.

SOPER, Circuit Judge.

This case brings up for review the Tax Court's approval of determinations by the Commissioner of income tax deficiencies against the petitioning taxpayers for the years 1948 to 1950 inclusive. The taxpayers are Robert L. Nowland and Mary C. Nowland, his wife, Charles E. Nelson and Virginia M. Nelson, his wife, and the North Beach Amusement Company, Inc. The taxes in question were assessed upon (1) the income of a numbers game which was operated...

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