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SLOUGH v. COMMISSIONER OF INTERNAL REVENUE

No. 9854.

147 F.2d 836 (1945)

SLOUGH et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

February 14, 1945.

Attorney(s) appearing for the Case

J. Helen Slough Juergens, of Cleveland, Ohio (Frank M. Slough, of Cleveland, Ohio, on the brief), for petitioners.

Lyle M. Turner, of Washington, D. C., Samuel O. Clark, Jr., Sewall Key, Robert N. Anderson, and Ernest R. Mortenson, all of Washington, D. C., on the brief), for respondent.

Before SIMONS, ALLEN, and MARTIN, Circuit Judges.

MARTIN, Circuit Judge.

The United States Tax Court, three judges dissenting, held that the petitioners, a father and daughter in law partnership, were not entitled to the benefits conferred by the section added to the Revenue Act of 1939 on June 29, 1939, namely, Chapter 247, Title II, Section 220(a), 53 Stat. 878, 26 U.S.C.A. Int.Rev.Code, 107, which provides: "Compensation for Services Rendered for a Period of Five Years or More. In the case of compensation (a)...

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