WORM v. COMMISSIONER OF INTERNAL REVENUE

No. 4656.

61 F.2d 868 (1932)

WORM v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

Rehearing Denied December 27, 1932.


Attorney(s) appearing for the Case

Forney Johnston, of Birmingham, Ala. (Cabaniss & Johnston, of Birmingham, Ala., of counsel), for petitioner.

G. A. Youngquist, Asst. Atty. Gen., and Sewall Key and Wm. Cutler Thompson, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Byron M. Coon, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before ALSCHULER and SPARKS, Circuit Judges, and WILKERSON, District Judge.


WILKERSON, District Judge.

Section 213 of the Revenue Act of 1921, c. 136, 42 Stat. 227, 238, requires that for income tax purposes there shall be included "gains, profits, and income derived from * * * compensation for personal service * * * or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; * * * or gains or profits and income derived from any source whatever."

That section also...

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