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BROWN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 10051, 10052.

180 F.2d 926 (1950)

BROWN v. COMMISSIONER OF INTERNAL REVENUE (two cases).

United States Court of Appeals Third Circuit

Decided February 28, 1950.

Attorney(s) appearing for the Case

Scott P. Crampton, Washington, D. C. (Geo. E. H. Goodner, Washington, D. C., on the brief), for petitioners.

Melva M. Graney, Washington, D. C. (Theron Lamar Caudle, Assistant Attorney General, Ellis N. Slack, Special Assistant to the Attorney General, on the brief), for respondent.

Before BIGGS, Chief Judge, and MARIS and KALODNER, Circuit Judges.

MARIS, Circuit Judge.

These cases involve the deductibility as business expenses in computing the net taxable income of the taxpayers of certain rents and royalties paid by them to the trustee of two trusts created by them for the benefit of their children. They grow out of the following facts:

Taxpayers are husband and wife, residing in Clearfield, Pennsylvania. Their individual tax returns for the calendar year 1944 were filed on the cash receipts and disbursements...

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