HASH v. COMMISSIONER OF INTERNAL REVENUE

Nos. 5411, 5412.

152 F.2d 722 (1945)

HASH v. COMMISSIONER OF INTERNAL REVENUE (two cases).

Circuit Court of Appeals, Fourth Circuit.

December 31, 1945.


Attorney(s) appearing for the Case

Charles W. Moxley, of Charleston, W. Va. (Brown, Jackson & Knight, of Charleston, W. Va., on the brief), for petitioners.

Harry Baum, 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 SOPER and DOBIE, Circuit Judges, and COLEMAN, District Judge.


DOBIE, Circuit Judge.

These companion cases present a single question. Does the record here justify us in affirming a decision of the Tax Court of the United States that the rights retained by the taxpayers in the property transferred under partnership and trust agreements, were so many, so material and so substantial as to render taxpayers liable (as to the tax years in question) for taxes on the income from this property under the provisions of Section 22(a) of...

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