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KANN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 11066, 11067.

210 F.2d 247 (1953)

KANN et al. v. COMMISSIONER OF INTERNAL REVENUE. KANN'S ESTATE et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided December 31, 1953.

Rehearing Denied February 15, 1954.

Attorney(s) appearing for the Case

R. J. Cleary, Ferdinand T. Weil, Pittsburgh, Pa. (Andrew L. Weil, Pittsburgh, Pa., on the brief), for petitioner.

Meyer Rothwacks, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before GOODRICH, McLAUGHLIN and KALODNER, Circuit Judges.

McLAUGHLIN, Circuit Judge.

We are asked to review two decisions of the Tax Court, 18 T.C. 1032, upholding certain income tax deficiencies and fraud penalties for the years 1936 through 1941. Petitioners are W. L. Kann and Stella H. Kann, his wife, and the representatives of Gustave H. Kann, deceased.1

A summary of the leading facts as stipulated and found follows. G. H. and W. L. Kann were brothers...

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