HANNA v. COMMISSIONER OF INTERNAL REVENUE

Nos. 11070, 11071.

156 F.2d 135 (1946)

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

Circuit Court of Appeals, Ninth Circuit.

May 21, 1946.


Attorney(s) appearing for the Case

A. Calder Mackay and Adam Y. Bennion, both of Los Angeles, Cal., for petitioners.

Sewall Key, Acting Asst. Atty. Gen., and A. F. Prescott, Harold C. Wilkenfeld, and Spurgeon Avakian, Sp. Assts. to Atty. Gen., for respondent.

Before DENMAN, STEPHENS and ORR, Circuit Judges.


STEPHENS, Circuit Judge.

The Commissioner of Internal Revenue found deficiencies in income tax returns of Byron C. Hanna and his wife, Daisy May Hanna, for the year 1940. They each filed a petition with the Tax Court of the United States, alleging error in the denial of the application of Section 107 of the Internal Revenue Code1 to a fee received in 1940 by a law partnership of which Mr. Hanna...

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