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HALEY v. COMMISSIONER OF INTERNAL REVENUE

No. 14234.

203 F.2d 815 (1953)

HALEY et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

April 23, 1953.

Attorney(s) appearing for the Case

Henry Ravenel, Lawrence A. Baker, Baker, Selby & Ravenel, all of Washington, D. C., for petitioners.

C. Hoxley Featherston, Sp. Assts. to Atty. Gen., Carlton Fox, Charles S. Lyon, Asst. Atty. Gen., Ellis N. Slack, Acting Asst. Atty. Gen., Charles W. Davis, Chief Counsel, Bureau of Internal Revenue, Claude R. Marshall, Sp. Atty., Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and HOLMES and RIVES, Circuit Judges.

RIVES, Circuit Judge.

Petitioners seek review of a decision of the Tax Court assessing them with deficiencies in Federal income taxes for the calendar years 1944 and 1945. The opinion of the Tax Court is reported at 16 T.C. 1509.

Petitioner, D. G. Haley, and his wife, Anne M. Haley, filed joint returns for the tax years involved on the cash receipts and disbursements basis. In March, 1943, petitioner agreed with one William...

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