KALES v. WOODWORTH

No. 5105.

32 F.2d 37 (1929)

KALES v. WOODWORTH, Collector.

Circuit Court of Appeals, Sixth Circuit.

April 5, 1929.


Attorney(s) appearing for the Case

Hal H. Smith and Archibald Broomfield, both of Detroit, Mich. (Beaumont, Smith & Harris, of Detroit, Mich., on the brief), for plaintiff in error.

J. R. Wheeler, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, of Washington, D. C., John R. Watkins, U. S. Atty., and C. Frederick Stanton, Asst. U. S. Atty., both of Detroit, Mich., on the brief), for defendant in error.

Before MOORMAN, HICKENLOOPER, and KNAPPEN, Circuit Judges.


MOORMAN, Circuit Judge.

No objections or exceptions were taken in the court below to the findings of fact, and the case before us presents only questions of law upon the facts found. It involves income taxes for the years 1917 and 1919. The facts relating to the two assessments are somewhat alike. Those pertinent to the earlier assessment will appear from the discussion of the later one.

On July 31 of 1916 appellant was the owner of 525 shares of the capital...

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