WOFFORD v. COMMISSIONER OF INTERNAL REVENUE

No. 14225.

207 F.2d 749 (1953)

WOFFORD v. COMMISSIONER OF INTERNAL REVENUE. COMMISSIONER OF INTERNAL REVENUE v. WOFFORD.

United States Court of Appeals Fifth Circuit.

November 18, 1953.


Attorney(s) appearing for the Case

Harry Friedman, C. Leo DeOrsey, Washington, D. C., for petitioner.

F. E. Youngman, Atty. Dept. of Just., H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Acting Asst. Atty. Gen., Charles W. Davis, Chief Counsel, Bur. Int. Rev., John M. Morawski, Sp. Atty. Bur. Int. Rev., Washington, D. C., Morton K. Rothschild, Sp. Assts. to Atty. Gen., for respondent.

Before HUTCHESON, Chief Judge, and BORAH and RUSSELL, Circuit Judges.


HUTCHESON, Chief Judge.

These two petitions seeking a review of the decision of the Tax Court, one filed by the taxpayer and one by the Commissioner, involve claimed deficiencies in income taxes for the fiscal years ending June, 1941, 1942, and 1944.

The taxpayer's petition presents two substantial questions for our decision. One of these is whether the Tax Court erred in holding and deciding that the petitioner and his wife as trustees for their minor daughter...

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