BRADFORD v. COMMISSIONER OF INTERNAL REVENUE

No. 12550.

233 F.2d 935 (1956)

Eleanor A. BRADFORD, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

May 22, 1956.


Attorney(s) appearing for the Case

William Waller, Nashville, Tenn., (Lawrence Dortch, Waller, Davis & Lansden, Nashville, Tenn., on the brief), for petitioner.

Karl Schmeidler, Washington, D. C. (H. Brian Holland, Ellis N. Slack, Washington, D. C., on the brief), for respondent.

Before MARTIN, MILLER and STEWART, Circuit Judges.


STEWART, Circuit Judge.

The question here is whether the petitioner realized $50,000 income in 1946 when her liability upon a note for $100,000 was discharged for $50,000.

In 1938 the petitioner's husband owed a Nashville bank approximately $305,000. The debt had grown out of investment banking ventures he had engaged in prior to the depression. He had pledged most of his assets to the bank as collateral, but the...

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