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GUGENHEIM v. COMMISSIONER OF INTERNAL REVENUE

No. 15783.

239 F.2d 286 (1956)

Albert Dick GUGENHEIM and Esther Gladys Gugenheim, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

December 14, 1956.

Attorney(s) appearing for the Case

Wentworth T. Durant, Earle B. Mayfield, Jr., Robert J. Hobby, Dallas, Tex., for petitioners.

Marvin W. Weinstein, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, Carolyn R. Just, Attys., Dept. of Justice, Washington, D. C., John Potts Barnes, Chief Counsel, John M. Morawski, Sp. Atty., I. R. S., Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and RIVES and TUTTLE, Circuit Judges.

PER CURIAM.

This appeal involves federal income taxes for the calendar year ended December 31, 1947, in the amount of $2,545.90 for appellant, A. D. Gugenheim, Sr., and $2,545.90 for appellant, Esther Gladys Gugenheim. The deficiencies result from a determination by the Commissioner of Internal Revenue: (1) that appellants' daughter, Bette Ann Manhein, and her husband, James Manhein, were not members of a family partnership between appellants, their son, and the Manheins...

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