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KENWORTHY v. COMMISSIONER OF INTERNAL REVENUE

Nos. 10719-10724.

197 F.2d 525 (1952)

N. Paul KENWORTHY and Dorothy F. Kenworthy, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Thomas KENWORTHY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. N. Paul KENWORTHY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Thomas KENWORTHY, III, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Thomas KENWORTHY, and Marie Kenworthy, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Thomas KENWORTHY, III, and Mary Wells Kenworthy, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided June 30, 1952.

Attorney(s) appearing for the Case

James A. Moore, Philadelphia, Pa. (Richard C. Sorlien, Ernest Scott, Philadelphia, Pa., Pepper, Bodine, Stokes & Hamilton, Philadelphia, Pa., on the brief), for petitioners.

Harry Marselli, Washington, D. C. (Ellis N. Slack, Acting Asst. Atty. Gen., A. F. Prescott, I. Henry Kutz, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before MARIS, McLAUGHLIN and HASTIE, Circuit Judges.

PER CURIAM.

The issue raised by these petitions to review decisions of the Tax Court determining the income tax liability of the petitioners for the years 1947 and 1948 is whether the court erred in holding that the entire sum of $227,623.46 paid by the partnership of Thos. Kenworthy's Sons, of which the male petitioners are members, to Oscar A. Fow, a former partner, in connection with his assignment to the remaining partners of his interest in the partnership, was...

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