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JACKSON v. COMMISSIONER OF INTERNAL REVENUE

No. 267, Docket 23891.

233 F.2d 289 (1956)

Howard A. JACKSON and Elizabeth D. Jackson, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided May 3, 1956.

Attorney(s) appearing for the Case

Ewing Everett (New York City), David W. Richmond, Numa L. Smith, Jr. and Miller & Chevalier, of counsel (Washington, D. C.), for petitioners.

Charles K. Rice, Acting Asst. Atty. Gen., Lee A. Jackson and Melva M. Graney, Attorneys, Department of Justice (Washington, D. C.), for respondent.

Before FRANK, MEDINA and WATERMAN, Circuit Judges.

FRANK, Circuit Judge.

The basic question here is whether certain corporations should be disregarded with the result that transactions carried out by them should be treated as if the corporations did not exist and as if the transactions had been those of the taxpayers themselves. The facts are fully stated in the opinion of the Tax Court, reported 24 T.C. 1, and we need but briefly summarize them here.

Taxpayers and two others...

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