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ARTHUR R. JONES SYNDICATE v. COMMISSIONER OF I. REVENUE

No. 3910.

23 F.2d 833 (1927)

ARTHUR R. JONES SYNDICATE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

December 1, 1927.

Attorney(s) appearing for the Case

David K. Tone, of Chicago, Ill., for petitioner.

Ottamar Hamele, of Washington, D. C., for respondent.

Before ALSCHULER, EVANS, and ANDERSON, Circuit Judges.

EVAN A. EVANS, Circuit Judge.

Respondent assessed a tax against petitioner upon an alleged income of $29,166.65. The taxpayer protested. It claimed a deduction of this sum as an interest charge. Whether it was paid to one Austin as an interest charge or as a dividend on preferred stock is the sole question presented on this appeal. The statement of facts will be directed to this single issue.

The Jones Syndicate was organized to promote a real estate venture...

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