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POPE v. COMMISSIONER OF INTERNAL REVENUE

No. 6724.

77 F.2d 599 (1935)

POPE et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

May 14, 1935.

Attorney(s) appearing for the Case

Raymond K. Dykema, of Detroit, Mich. (Benjamin J. Manley and Dykema, Jones & Wheat, all of Detroit, Mich., on the brief), for petitioners.

Frank J. Wideman, of Washington, D. C. (Sewall Key and Helen R. Carloss, both of Washington, D. C., on the brief), for respondent.

Before MOORMAN, SIMONS, and ALLEN, Circuit Judges.

MOORMAN, Circuit Judge.

Each of the petitioners is a retired civil engineer and a resident of Detroit, Mich. Prior to 1921 they were employed by the Canadian Bridge Company, which had its main office in Walkerville, Ontario. In 1919 Charles T. Miller, secretary-treasurer of the bridge company, became interested in the purchase of two tracts of land near Walkerville and Windsor, Ontario. At his suggestion a number of men, including the petitioners, formed a syndicate...

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