MASSEY v. COMMISSIONER OF INTERNAL REVENUE

No. 10927.

143 F.2d 429 (1944)

MASSEY et al. v. COMMISSIONER OF INTERNAL REVENUE. COMMISSIONER OF INTERNAL REVENUE v. MASSEY et al. SAME v. MASSEY (two cases).

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied September 23, 1944.


Attorney(s) appearing for the Case

William Benson Massey, of Shreveport, La., for taxpayers.

Joseph M. Jones, Sewall Key, and Helen R. Carloss, Sp. Assts. to Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and John M. Morawski, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.


HOLMES, Circuit Judge.

This case presents four petitions for review involving asserted deficiencies in income taxes of W. B. Massey and his wife. The questions presented relate to the tax incidence of cash and oil interests received by Massey as payment for legal services rendered. The proceedings were consolidated before the Board of Tax Appeals, and the petitions for review were consolidated for hearing and adjudication in this court.

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