CROWELL v. COMMISSIONER OF INTERNAL REVENUE

Nos. 6002, 6003.

62 F.2d 51 (1932)

CROWELL v. COMMISSIONER OF INTERNAL REVENUE. LITTLE v. SAME.

Circuit Court of Appeals, Sixth Circuit.

December 6, 1932.


Attorney(s) appearing for the Case

I. W. Sharp, of Cleveland, Ohio (F. X. Cull and Bulkley, Hauxhurst, Inglis & Sharp, all of Cleveland, Ohio, on the brief), for petitioners.

A. G. Divet, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, C. M. Charest, and Arthur Carnduff, all of Washington, D. C., on the brief), for respondent.

Before MOORMAN, HICKENLOOPER, and SIMONS, Circuit Judges.


SIMONS, Circuit Judge.

Both appeals are from decisions of the Board of Tax Appeals based upon one set of findings, and by stipulation here consolidated. The controversy involves the test that, under the applicable statute and regulations, must be applied to determine value for income tax purposes of shares of stock received as compensation for personal services, and the effect of the presumption that the commissioner's determination is correct.

The petitioners...

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