SUNNEN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 13425, 13426.

161 F.2d 171 (1947)

SUNNEN v. COMMISSIONER OF INTERNAL REVENUE. COMMISSIONER OF INTERNAL REVENUE v. SUNNEN.

Circuit Court of Appeals, Eighth Circuit.

April 28, 1947.


Attorney(s) appearing for the Case

C. P. Fordyce, of St. Louis, Mo., for Joseph Sunnen.

Hilbert P. Zarky, Sp. Asst. to Atty. Gen. (Sewall Key, Acting Asst. Atty. Gen., and Robert N. Anderson and Helen Goodner, Sp. Assts. to Atty. Gen., on the brief), for Commissioner of Internal Revenue.

Before GARDNER, THOMAS, and RIDDICK, Circuit Judges.


THOMAS, Circuit Judge.

These two petitions to review a single decision of the Tax Court present identical or similar questions for determination. By stipulation of the parties the cases have been consolidated here for briefing and argument and will accordingly be disposed of by us in one opinion.

The questions presented are: (1) Whether the petitioner, Joseph Sunnen, is taxable under § 22(a) of the Revenue Act of 1936, 49 Stat. 1648, 26 U.S.C.A. Internal...

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