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HELVERING v. BARTLETT

No. 3625.

71 F.2d 598 (1934)

HELVERING, Com'r of Internal Revenue, v. BARTLETT.

Circuit Court of Appeals, Fourth Circuit.

June 11, 1934.

Attorney(s) appearing for the Case

Lucius A. Buck, Sp. Asst. to Atty. Gen. (Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

J. Kemp Bartlett, of Baltimore, Md. (Bartlett, Poe & Claggett and C. Ross McKenrick, all of Baltimore, Md., on the brief), for respondent.

A. Mitchell Palmer, of Stroudsburg, Pa., Wm. D. Harris, of Washington, D. C., and Francis V. Barstow, of Boston, Mass., amici curiæ.

Before PARKER and NORTHCOTT, Circuit Judges, and PAUL, District Judge.

PARKER, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals. The Commissioner of Internal Revenue made a deficiency assessment against J. Kemp Bartlett based on the addition to his income for the year 1929 of the sum of $21,246.60, being the value of 20,830 "rights" to subscribe to stock in the United States Fidelity & Guaranty Fire Corporation, which were allotted him as a stockholder in the United States Fidelity & Guaranty...

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