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GIBSON v. COMMISSIONER OF INTERNAL REVENUE

No. 5984.

83 F.2d 869 (1936)

GIBSON v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

May 18, 1936.

Attorney(s) appearing for the Case

Earl F. Reed, C. M. Thorp, Jr., John E. Laughlin, Jr., and Thorp, Bostwick, Reed & Armstrong, all of Pittsburgh, Pa., for petitioner.

Maurice J. Mahoney and Sewall Key, Sp. Assts. to the Atty. Gen., for respondent.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

BUFFINGTON, Circuit Judge.

In this tax case the facts are undisputed, and the question involved is the legal liability of the taxpayer. The pertinent facts are as follows: Though the taxpayer, Addison H. Gibson, was president and director of the Gibson-Zahniser Oil Corporation, hereafter called Zahniser, he owned no stock therein and devoted very little time to its affairs, Dickson being the manager thereof.

All of Zahniser's preferred and two-thirds of its...

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