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COMMISSIONER OF INTERNAL REVENUE v. PETERMAN

No. 9546.

118 F.2d 973 (1941)

COMMISSIONER OF INTERNAL REVENUE v. PETERMAN et al.

Circuit Court of Appeals, Ninth Circuit.

April 4, 1941.

Attorney(s) appearing for the Case

Samuel O. Clark, Asst. Atty. Gen., Sewall Key, J. Louis Monarch, Edward M. English, and Morten K. Rothschild, Sp. Assts. to Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, of Washington, D.C., for petitioner.

J. P. Patten, of Seattle, Wash., for respondent.

Before GARRECHT, HANEY, and STEPHENS, Circuit Judges.

GARRECHT, Circuit Judge.

The respondents filed separate petitions in the United States Board of Tax Appeals for redetermination of an asserted deficiency in the income tax of each for the calendar year 1936. The four petitions were consolidated for hearing and decision in the Board of Tax Appeals, and the facts stipulated. The Board rendered a memorandum opinion, which is not reported. Only a part of each asserted deficiency was in controversy, and as to that part...

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