RONEY v. COMMISSIONER OF INTERNAL REVENUE

No. 3492.

67 F.2d 165 (1933)

RONEY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

October 3, 1933.


Attorney(s) appearing for the Case

Wilton H. Wallace, of Washington, D. C. (E. F. Colladay, Joseph C. McGarraghy, and Colladay, McGarraghy, Colladay & Wallace, all of Washington, D. C., on the brief), for petitioner.

William Cutler Thompson, Sp. Asst. to Atty. Gen. (Sewall Key and J. P. Jackson, Sp. Assts. to Atty. Gen., and E. Barrett Prettyman, Gen. Counsel, Bureau of Internal Revenue, and J. A. Lyons, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before PARKER, NORTHCOTT, and SOPER, Circuit Judges.


NORTHCOTT, Circuit Judge.

This is a petition to review a decision of the United States Board of Tax Appeals involving income tax of the petitioner for the year 1928 in the amount of $35,373.07. The opinion of the Board of Tax Appeals is reported in 26 B. T. A. 1213. The facts were stipulated and are as follows:

In 1919 the petitioner and one Morris Schapiro, who were engaged in the wholesale scrap iron and metal business, purchased from the Gwynnbrook Distillery...

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