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JOHNSON v. COMMISSIONER OF INTERNAL REVENUE

No. 7116.

233 F.2d 752 (1956)

Jesse JOHNSON and Virginia D. Johnson, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided May 25, 1956.

Attorney(s) appearing for the Case

David R. Shelton, Washington, D. C., for petitioners.

Meyer Rothwacks, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and I. Henry Kutz, Attys, Dept. of Justice, Washington, D. C., on brief), for respondent.

Before PARKER, Chief Judge, DOBIE, Circuit Judge, and PAUL, District Judge.

PARKER, Chief Judge.

This is a petition to review a decision of the Tax Court of the United States affirming deficiency assessments of income taxes against petitioners, husband and wife, for the years 1947 and 1948, on the ground that certain deductions claimed as losses should not be allowed. The losses claimed were expenditures made by the husband, whom we shall refer to hereafter as the taxpayer, in constructing a building under contract for Frederick Courts, Inc...

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