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ROUGHAN v. COMMISSIONER OF INTERNAL REVENUE

No. 6442.

198 F.2d 253 (1952)

ROUGHAN v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fourth Circuit.

Decided July 31, 1952.

Attorney(s) appearing for the Case

C. F. Rothenburg, Washington, D. C. (Charles D. Hamel, Lee I. Park, and Hamel, Park & Saunders, Washington, D. C., on the brief), for petitioner.

S. Dee Hanson, Sp. Asst. to Atty. Gen. (Ellis N. Slack, Acting Asst. Atty. Gen., and Harry Baum, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PARKER, Chief Judge, and SOPER and DOBIE, Circuit Judges.

DOBIE, Circuit Judge.

This is an appeal from a decision of the Tax Court of the United States sustaining a deficiency assessment against the taxpayer on income taxes alleged to be due for the years 1944 and 1945 in the respective amounts of $218,762.80 and $63,816.75. This deficiency was based on the Commissioner's refusal to recognize the taxpayer's parents, wife, and son as partners for federal income tax purposes during the years in question. The Commissioner included...

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