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COMMISSIONER OF INTERNAL REVENUE v. THOMPSON

Nos. 11370, 11371, 11373, 11374.

222 F.2d 893 (1955)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Murray THOMPSON, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Kibbey W. COUSE, Respondent. Murray THOMPSON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Kibbey W. COUSE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided May 27, 1955.

Attorney(s) appearing for the Case

Israel B. Greene, Newark, N. J. (Bernard Hellring, Newark, N. J., on the brief), for taxpayers.

Dudley J. Godfrey, Jr., Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, A. F. Prescott, Special Assts. to the Atty. Gen., on the brief), for Commissioner.

Before McLAUGHLIN, KALODNER and HASTIE, Circuit Judges.

KALODNER, Circuit Judge.

The taxpayers and the Commissioner have appealed from the decisions of the Tax Court fixing the value of certain contracts at $250,000. 21 T.C. 448. The taxpayers contend that on the evidence the value could only have been fixed somewhere between $750,000 and $854,000. The Commissioner contends that the value must be deemed to be zero because the evidence affords no basis for valuation, but contrarily, if it...

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