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THOMPSON v. UNITED STATES

No. 9285.

110 F.2d 585 (1940)

THOMPSON v. UNITED STATES.

Circuit Court of Appeals, Fifth Circuit.

March 26, 1940.

Attorney(s) appearing for the Case

Earle W. Wallick, of Washington, D. C., for appellant.

Louise Foster, Sewall Key, and S. Dee Hanson, Sp. Assts. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., Herbert S. Phillips, U. S. Atty., of Tampa, Fla., and Harry G. Taylor, Sp. Asst. to the U. S. Atty., of Miami, Fla., for the United States.

Before SIBLEY, HUTCHESON, and HOLMES, Circuit Judges.

HUTCHESON, Circuit Judge.

The suit was for refund of income taxes. The claim was: that sums determined by the Commissioner as income received by plaintiff, were not income to him, but were; (1) received by him, as agent for, or as a joint adventurer with, and as the income of, Thompson and Company, a corporation solely owned by him; or (2) had been paid to the corporation for services rendered him, (a) pursuant to a valid contract, or (b) as reasonable compensation...

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