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HAY v. COMMISSIONER OF INTERNAL REVENUE

No. 5269.

145 F.2d 1001 (1944)

HAY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

November 13, 1944.

Attorney(s) appearing for the Case

Joseph D. Brady, of Los Angeles, Cal., (Brady & Nossaman and Walter L. Nossaman, all of Los Angeles, Cal., on the brief), for petitioner.

Warren F. Wattles, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PARKER, SOPER, and DOBIE, Circuit Judges.

SOPER, Circuit Judge.

The petition for review questions a decision of the Tax Court which held that William C. Hay, a British subject, was liable to an additional income tax in excess of $600,000 for the year 1937 upon the liquidation of William C. Hay, Ltd., a California corporation. There is no serious question of fact since the findings of the Tax Court were supported by abundant evidence, which is summarized in the following recital: Hay was born a British subject...

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