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HOUGLAND v. COMMISSIONER OF INTERNAL REVENUE

No. 10442.

166 F.2d 815 (1948)

HOUGLAND v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

March 22, 1948.

Attorney(s) appearing for the Case

Charles I. Dawson, of Louisville, Ky. (Woodward, Dawson, Hobson & Fulton, Chas. I. Dawson, A. Shelby Winstead and Bernard H. Barnett, all of Louisville, Ky., on the brief), for petitioner.

Louise Foster, of Washington, D. C. (Theron L. Caudle, George A. Stinson, A. F. Prescott and S. Dee Hanson, all of Washington, D. C., on the brief), for respondent.

Before SIMONS, ALLEN, and MARTIN, Circuit Judges.

MARTIN, Circuit Judge.

The Tax Court held that the Commissioner of Internal Revenue rightly included in the gross income of the petitioner, Walter G. Hougland, Jr., all the income for the year 1940 from a partnership arrangement between petitioner and his mother and his wife.

The record shows that the petitioner, by means of the financial assistance of his father by whom he was employed, purchased a towboat for $158,000; and, under the name "Hougland's," engaged...

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