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KENNEY v. COMMISSIONER OF INTERNAL REVENUE

Nos. 9154, 9155.

111 F.2d 374 (1940)

KENNEY v. COMMISSIONER OF INTERNAL REVENUE (two cases).

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied June 11, 1940.

Attorney(s) appearing for the Case

Wm. H. Talbot and John J. Finnorn, both of New Orleans, La., for petitioner in each case.

Helen R. Carloss and Sewall Key, Sp. Assts. to Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Ralph F. Staubly, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent in each case.

Before SIBLEY, HUTCHESON, and HOLMES, Circuit Judges.

HOLMES, Circuit Judge.

These two cases are brought to this court by petitions for review of decisions of the United States Board of Tax Appeals. The petition of Courtney A. Kenney involves deficiencies in income taxes for the years 1928, 1929, 1930, and 1931, together with a fifty per cent fraud penalty for each of said years.

The petition of Mrs. Kenney involves a deficiency for the year 1931. Except for the fact that no fraud penalty was imposed, her case...

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