DORZBACK v. COLLISON

Civ. No. 1138.

93 F.Supp. 935 (1950)

DORZBACK v. COLLISON, Collector of Internal Revenue.

United States District Court D. Delaware.

October 25, 1950.


Attorney(s) appearing for the Case

Morris Wolf and Samuel H. Levy (of Wolf, Block, Schorr & Solis-Cohen), of Philadelphia, Pa., and S. Samuel Arsht (of Morris, Steel, Nichols & Arsht), of Wilmington, Del., for plaintiff.

William Marvel, U. S. Atty., and Francis A. Reardon, Asst. U. S. Atty., of Wilmington, Del., and Theron Lamar Caudle, Asst. Atty. Gen., and Andrew D. Sharpe and Paul S. McMahon, Special Assts. to the Atty. Gen., for defendant.


LEAHY, Chief Judge.

Plaintiff sought recovery of $20,159.46 of income taxes and interest paid to the Delaware Collector for 1943-44-45. The case was tried by jury. Two issues were presented: (1) Were amounts paid by taxpayer to wife (representing 25% of the net income of his clothing store business) in lieu of interest on a debt he owed her deductible from gross income; and (2) were amounts paid to son reasonable compensation for services actually rendered by son...

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