SPARKS v. COMMISSIONER OF INTERNAL REVENUE

No. 11803.

238 F.2d 845 (1956)

Harry L. SPARKS and Rex Wanda Sparks, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

December 3, 1956.


Attorney(s) appearing for the Case

William P. Rosenthal, Leonard Schanfield, Chicago, Ill., for petitioners.

Charles K. Rice, Asst. Atty. Gen., Karl Schmeidler, Atty., U. S. Dept. of Justice, Washington, D. C., Lee A. Jackson, I. Henry Kutz, David O. Walter, Attys., Tax Division, Washington, D. C., for respondent.

Before DUFFY, Chief Judge, and LINDLEY, and SCHNACKENBERG, Circuit Judges.


SCHNACKENBERG, Circuit Judge.

This is an appeal from a decision of the tax court of the United States determining deficiencies in petitioners' income tax liability for the calendar years 1948 and 1949. They are husband and wife.1 Their son, Joe C. Sparks, was born February 19, 1938. The relevant income came from a business of buying and selling hogs. In said calendar years, 15% was allocated by taxpayer to Joe as an alleged partner in...

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