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COMMISSIONER OF INTERNAL REVENUE v. MORAN

No. 15505.

236 F.2d 595 (1956)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Richard E. and Helen MORAN, Respondents.

United States Court of Appeals Eighth Circuit.

Rehearing Denied October 8, 1956.

Attorney(s) appearing for the Case

Walter R. Gelles, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Acting Asst. Atty. Gen., and Lee A. Jackson and Harry Baum, Attys., Dept. of Justice, Washington, D. C., on the brief), for petitioner.

J. Weston Miller, Springfield, Mo. (Perry A. Ennis and Miller, Fairman & Sanford, Springfield, Mo., on the brief), for respondents.

Before SANBORN, WOODROUGH and VOGEL, Circuit Judges.

VOGEL, Circuit Judge.

The Commissioner of Internal Revenue has petitioned for a review of a decision rendered by the Tax Court of the United States. The facts of the single issue to be reviewed are not in dispute.

The taxpayers, husband and wife, were co-partners operating the Hotel Moran in Springfield, Missouri. Both are experienced hotel operators and participated extensively in the management of this hotel. In performing their various duties, it was necessary...

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