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THOMAS v. COMMISSIONER OF INTERNAL REVENUE

Nos. 10503, 10504.

135 F.2d 378 (1943)

THOMAS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

May 5, 1943.

Attorney(s) appearing for the Case

Ed. J. deVerges, of New Orleans, La., for petitioners.

Ray A. Brown and Sewall Key, Sp. Assts. to Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, McCORD, and WALLER, Circuit Judges.

WALLER, Circuit Judge.

The petitions are for review of decisions of the Board of Tax Appeals sustaining the Commissioner's determination of income tax deficiencies for the year 1936 against James Thomas and his wife, Rosalie Segari Thomas.

In 1936 the Louisiana Culvert Company, Inc., paid, in the form of a gift, to its secretary-manager, James Thomas, the sum of $25,000 which the Board determined in its findings of fact to be compensation for services rendered...

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