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BRITT'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 13394.

190 F.2d 946 (1951)

BRITT'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

August 4, 1951.

Attorney(s) appearing for the Case

Douglas D. Felix, Miami, Fla., for petitioner.

Melva M. Graney, Ellis N. Slack, Sp. Assts. to Atty. Gen., Dept. of Justice, Washington, D. C., Theron Lamar Caudle, Asst. Atty. Gen., Charles Oliphant, Chief Counsel, Bureau of Internal Revenue, Washington, D. C., Charles E. Lowery, Atty., Bureau of Internal Revenue, Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and SIBLEY and STRUM, Circuit Judges.

STRUM, Circuit Judge.

These two consolidated petitions to review the Tax Court involve income and estate tax deficiencies determined by the Commissioner of Internal Revenue, and sustained by the Tax Court,1 against the estate of Morgan C. Britt, deceased. Each of said deficiencies rests upon the Commissioner's determination that a family partnership, alleged to be composed of Britt, his wife and three children, is invalid for tax purposes...

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