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VAN SCIVER v. ROTHENSIES

No. 7704.

122 F.2d 697 (1941)

VAN SCIVER v. ROTHENSIES, Collector of Internal Revenue.

Circuit Court of Appeals, Third Circuit.

September 3, 1941.

Attorney(s) appearing for the Case

George P. Orr, of Philadelphia, Pa. (T. F. Dixon Wainwright, John W. Bohlen, and Orr, Hall & Williams, all of Philadelphia Pa., on the brief), for appellant.

Carolyn E. Agger, Sp. Asst. to Atty. Gen., and Gerald A. Gleeson, U. S. Atty., and Thos. J. Curtin, Asst. U. S. Atty., both of Philadelphia, Pa. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to the Atty. Gen., on the brief), for appellee.

Before BIGGS, CLARK, and JONES, Circuit Judges.

CLARK, Circuit Judge.

The appellant taxpayer, as often, has elected to come to us through the District Court rather than through the Board of Tax Appeals.1 He complains of the imposition of additional tax ($3,661.15) on income which he says is not his but his son's. This claim emanates from a paternal "rescue party." The son, Earl J. Van Sciver, had borrowed money from a bank. The collateral against this loan, along with most collateral...

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