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CHATTANOOGA AUTO. CLUB v. COMMISSIONER OF INT. REV.

Nos. 11017, 11016.

182 F.2d 551 (1950)

CHATTANOOGA AUTOMOBILE CLUB v. COMMISSIONER OF INTERNAL REVENUE. WARREN AUTOMOBILE CLUB, Inc. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

June 1, 1950.

Attorney(s) appearing for the Case

John Ross Scott, Chattanooga, Tenn. (John Ross Scott, Chattanooga, Tenn., on the brief), for Warren Automobile Club, Inc.

Carl H. Tangeman, Columbus, Ohio (I. G. Stirgwolt, Columbus, Ohio, Vorys, Sater, Seymour & Pease, Columbus, Ohio, on the brief), for Chattanooga Automobile Club.

Irving I. Axelrad, Washington, D. C. (Theron Lamar Caudle, Ellis N. Slack, and Sumner M. Redstone, Washington, D. C., on the brief), for respondent.

Before SIMONS, MARTIN and MILLER, Circuit Judges.

MARTIN, Circuit Judge.

In both these cases, the petitioners seek review and reversal of decisions of the United States Tax Court upholding determinations by the Commissioner of Internal Revenue of deficiencies in income tax and declared value excess-profits tax for their respective fiscal years ending during 1944. Though argued and submitted separately, the controlling issue in each case is the same. We will, therefore, announce decision in both cases in one opinion...

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