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HAMME v. COMMISSIONER OF INTERNAL REVENUE

No. 6689.

209 F.2d 29 (1953)

HAMME et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fourth Circuit.

Decided December 31, 1953.

Attorney(s) appearing for the Case

Stanley Worth and Edward S. Smith, Washington, D. C. (Blair, Korner, Doyle & Appel, Washington, D. C., on the brief), for petitioners.

Carolyn R. Just, Sp. Asst. to the Atty. Gen. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack and A. F. Prescott, Sp. Assts. to the Atty. Gen. on the brief), for respondent.

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

DOBIE, Circuit Judge.

These are appeals from judgments of the Tax Court of the United States which held net deficiencies to exist in the income tax returns of petitioners, Joseph Hamme and R. H. Hamme, for the years 1944, 1945, 1946 and 1947. The decisions were based on determinations that amounts received under a contract dated March 4, 1944, were, for federal income tax purposes, royalties from mining rights and taxable as ordinary income. Petitioners contended...

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