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SIMON J. MURPHY CO. v. COMMISSIONER OF INTERNAL REV.

No. 12491.

231 F.2d 639 (1956)

SIMON J. MURPHY COMPANY and Social Research Foundation, Inc., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

April 2, 1956.

Attorney(s) appearing for the Case

Berrien C. Eaton, Jr., Detroit, Mich. (Edward S. Reid, Jr., Miller, Canfield, Paddock & Stone, Detroit, Mich., on the brief), for petitioners.

Stanley P. Wagman, Washington, D. C. (H. Brian Holland, Ellis N. Slack and Robert N. Anderson, Washington, D. C., on the brief), for respondent.

Before SIMONS, Chief Judge, and ALLEN and MILLER, Circuit Judges.

SHACKELFORD MILLER, Jr., Circuit Judge.

The petitioners seek a redetermination of income tax deficiencies assessed by the Commissioner for the years 1949 and 1950. The assessments were approved by the Tax Court in the amount of $8,338.06 for the year 1949 and in the amount of $6,094.84 for the year 1950, which ruling is now before us for review.

The facts are stipulated and are summarized as follows: The Simon J. Murphy

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