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COBB v. COMMISSIONER OF INTERNAL REVENUE

No. 11135.

185 F.2d 255 (1950)

COBB v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

December 4, 1950.

Attorney(s) appearing for the Case

Briggs G. Simpich, Washington, D. C. (Briggs G. Simpich, Washington, D. C., on the brief), for petitioner.

S. Dee Hanson, Washington, D. C. (Theron Lamar Caudle, Ellis N. Slack, and S. Dee Hanson, all of Washington, D. C., on the brief), for respondent.

Before HICKS, Chief Judge, and SIMONS, and McALLISTER, Circuit Judges.

SIMONS, Circuit Judge.

Once again we are confronted with the problem of the result, taxwise, in the creation of a family partnership. The diverse interpretations that have been given by courts to the rationale of Commissioner of Internal Revenue v. Tower, 327 U.S. 280, 66 S.Ct. 532, 90 L.Ed. 670, need no longer trouble us in view of the illumination shed upon that case by the careful reasoning of the court in the later case of Commissioner...

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