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SINGLETARY v. COMMISSIONER OF INTERNAL REVENUE

No. 11573.

155 F.2d 207 (1946)

SINGLETARY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

May 14, 1946.

Attorney(s) appearing for the Case

Philip H. Alston, of Atlanta, Ga., and S. P. Cain, of Cairo, Ga., for petitioner.

Maryhelen Wigle, A. F. Prescott, and S. Dee Hanson, Sp. Assts. to Atty. Gen., Sewall Key, Acting Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Claude R. Marshall, Sp. Atty., Bureau of Internal Revenue, both of Washington D. C., for respondent.

Before HOLMES, McCORD, and WALLER, Circuit Judges.

WALLER, Circuit Judge.

The subject matter of this case is the income tax consequences of a family partnership which, in 1940, was composed of the husband and wife, and, in 1941, was enlarged to include also the father and mother of the husband.

Lewis Hall Singletary, the taxpayer, and his wife, Mildred, married in 1929, before and after which time she worked as a teacher and as a secretary while he ran a filling station. From their joint earnings they acquired...

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