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HOGLE v. COMMISSIONER OF INTERNAL REVENUE

No. 2566.

132 F.2d 66 (1942)

HOGLE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Tenth Circuit.

November 25, 1942.

Attorney(s) appearing for the Case

John Enrietto, of Washington, D. C. (Charles D. Hamel, of Washington, D. C., G. A. Marr, C. W. Wilkins, and Cheney, Jensen, Marr & Wilkins, all of Salt Lake City, Utah, and Hamel, Park & Saunders, of Washington, D. C., on the brief), for petitioner.

L. W. Post, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to Atty.Gen., on the brief), for respondent.

Before PHILLIPS, BRATTON, and HUXMAN, Circuit Judges.

PHILLIPS, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals and involves income taxes for the years 1934 to 1937, inclusive, assessed against James A. Hogle, petitioner. The Board held that all of the income in question was taxable to Hogle under § 22(a) of the Revenue Acts of 1934 and 1936, 26 U.S.C.A. Int. Rev.Acts, pages 669, 825.

Hogle and Mary C. Hogle, his wife, reside in Salt Lake City, Utah. They have three children...

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