BELSER v. COMMISSIONER OF INTERNAL REVENUE

No. 5864.

174 F.2d 386 (1949)

BELSER v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fourth Circuit.

May 2, 1949.


Attorney(s) appearing for the Case

W. Croft Jennings and Carlisle Roberts, both of Columbia, S. C., for petitioner.

Fred E. Youngman, Sp. Asst. to Atty., Gen., (Theron Lamar Caudle, Asst. Atty. Gen., and Ellis N. Slack and A. F. Prescott, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before PARKER, Chief Judge, and SOPER and DOBIE, Circuit Judges.


DOBIE, Circuit Judge.

This appeal, taken from a decision of the Tax Court of the United States, involves a deficiency of $3,675.66 in the federal income tax for the calendar year 1932 of Irvine F. Belser, plus a penalty of $918.92 for taxpayer's failure to file a timely return for that year.

Taxpayer's appeal questions three findings of the Tax Court:

(1) That taxpayer's stock in the Fairview Farming Company, a corporation, on which taxpayer claimed...

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