STUART v. COMMISSIONER OF INTERNAL REVENUE

Nos. 7695, 7696.

124 F.2d 772 (1941)

STUART v. COMMISSIONER OF INTERNAL REVENUE. STUART v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

December 19, 1941.


Attorney(s) appearing for the Case

Herbert Pope, W. D. McKenzie, Benjamin M. Price, and Geo. I. Haight, all of Chicago, Ill., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., J. P. Wenchel, Bureau of Internal Revenue, of Washington, D. C., Bernard Chertcoff, and Gerald L. Wallace, Sp. Assts. to Atty. Gen., for respondent.

Before SPARKS, MAJOR, and MINTON, Circuit Judges.


SPARKS, Circuit Judge.

These petitions seek to review decisions of the United States Board of Tax Appeals. We shall treat them in the order of their numbers.

In the case of John Stuart, the Commissioner determined income tax deficiencies against him for the years 1934 and 1935. The Board confirmed that ruling and held that under Section 166(2) of the Revenue Act of 1934, 26 U.S.C.A.Int.Rev.Code, § 166(2), petitioner was taxable on the net income of three...

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