PELTON v. COMMISSIONER OF INTERNAL REVENUE

Nos. 5619, 5620.

82 F.2d 473 (1936)

PELTON et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

March 20, 1936.


Attorney(s) appearing for the Case

John L. Hopkins, of Chicago, Ill. (Marcus Whiting, Leo T. Norville, George F. James, George E. McMurray, and Frank J. Delany, Jr., all of Chicago, Ill., of counsel), for petitioners.

Frank J. Wideman, Asst. Atty. Gen., Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., and Joseph M. Jones, of Washington, D. C., for respondent.

Before EVANS and SPARKS, Circuit Judges, and LINDLEY, District Judge.


SPARKS, Circuit Judge.

Deficiencies in income taxes were determined against petitioners by the Commissioner of Internal Revenue for the years 1924, 1925, 1926 and 1927, upon the ground that the Pelton Clinic was an association within the meaning of section 2 (a) (2) of the Revenue Acts of 1924 and 1926, 26 U.S.C.A. § 1696 and note. Appeals were taken from two decisions of the Board of Tax Appeals which confirmed the determination of the Commissioner. They involve...

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