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LENGSFIELD v. COMMISSIONER OF INTERNAL REVENUE

No. 16000.

241 F.2d 508 (1957)

Ruth T. LENGSFIELD, Coralie Mayer Lengsfield and Blanche L. Brown, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

February 27, 1957.

Attorney(s) appearing for the Case

Albert B. Koorie, New Orleans, La., Roehner & Roehner, New York City, of counsel, for petitioner.

George F. Lynch, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., John Potts Barnes, Chief Counsel, Internal Revenue Service, John M. Morawski, Sp. Atty., Internal Revenue Service, Lee A. Jackson, A. F. Prescott, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and CAMERON and JONES, Circuit Judges.

HUTCHESON, Chief Judge.

This appeal involves deficiencies in income tax determined by the Commissioner against the taxpayers for the calendar years 1947 to 1950, and sustained by the Tax Court in findings of fact1 and an opinion not officially reported.

The sole question presented is whether the Tax Court erred in holding that monthly payments received by taxpayers from a corporation in...

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