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PARAMOUNT-RICHARDS TH. v. COMMISSIONER OF INT. REV.

No. 11315.

153 F.2d 602 (1946)

PARAMOUNT-RICHARDS THEATRES, Inc., et al., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

February 15, 1946.

Attorney(s) appearing for the Case

Gibbons Burke, of New Orleans, La., for petitioners.

Harry Baum and A. F. Prescott, Sp. Assts. to Atty. Gen., Sewall Key, Acting Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Bernard D. Daniels, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.

McCORD, Circuit Judge.

The appeals here are from decisions of the Tax Court denying certain tax deductions claimed by Paramount-Richards Theatres, Inc., Ernest v. Richards, Jr., and his wife, Loretta McKenna Richards, for the years 1938 and 1939. Richards and his wife reported their income on the community property basis.

The important facts are these: In November 1934, Paramount Publix Corporation, a Delaware corporation, was involved in a reorganization...

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