BALLESTER-RIPOLL v. COURT OF TAX APPEALS OF P. R.

No. 3918.

142 F.2d 11 (1944)

BALLESTER-RIPOLL v. COURT OF TAX APPEALS OF PUERTO RICO et al.

Circuit Court of Appeals, First Circuit.

April 5, 1944.


Attorney(s) appearing for the Case

William Cattron Rigby, of Washington, D. C. (Oscar Souffront, of Mayaguez, P. R., and J. J. Ortiz-Alibran, of San Juan, P. R. (Rigby, Leon & Weill and Fred W. Llewellyn, all of Washington, D. C., of counsel), for appellant.

I. Henry Kutz, Sp. Asst. to the Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to the Atty. Gen., for appellees.

Before MAGRUDER, MAHONEY, and WOODBURY, Circuit Judges.


MAHONEY, Circuit Judge.

On March 15, 1941, the taxpayer and his wife filed separate income tax returns for the year 1940. Each reported a net income of $19,529.45, that amount being one-half of the income received from the same source, namely: salary from a partnership, directors fees from a partnership, directors fees from a corporation, interest on notes payable by a partnership, profits from an interest in a partnership and corporate dividends, all of which was...

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