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ROY v. COMMISSIONER OF INTERNAL REVENUE

No. 7169.

69 F.2d 786 (1934)

ROY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied April 21, 1934.

Attorney(s) appearing for the Case

John J. Finnorn, of New Orleans, La., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., Norman D. Keller and Sewall Key, Sp. Assts. to Atty. Gen., and E. Barrett Prettyman, Gen. Counsel, Bureau of Internal Revenue, and John H. Pigg, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before BRYAN, FOSTER, and HUTCHESON, Circuit Judges.

BRYAN, Circuit Judge.

The petitioner complains of deficiency assessments of his income taxes for the year 1923, which were made by the Commissioner of Internal Revenue and approved by the Board of Tax Appeals. The assessments were made upon income derived from contracts for the sale of real estate providing for payment of a part of the purchase price in cash and of the balance in installments. Petitioner during the taxable year involved was a member of a partnership...

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