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PEACOCK v. COMMISSIONER OF INTERNAL REVENUE

No. 16941.

256 F.2d 160 (1958)

Henry B. PEACOCK, Jr., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

June 13, 1958.

Attorney(s) appearing for the Case

Harry G. Taylor, Miami, Fla., for petitioner.

Davis W. Morton, Jr., Atty., Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, Attys., Nelson P. Rose, Chief Counsel Int. Rev. Service, John M. Morawski, Special Atty. Int. Rev. Service, Washington, D. C., for respondent.

Before CAMERON, JONES and BROWN, Circuit Judges.

JONES, Circuit Judge.

The Commissioner of Internal Revenue determined income tax deficiencies against Henry B. Peacock, Jr. for the years 1948, 1949 and 1950, which were, in part, sustained by the Tax Court. From those portions of its decision adverse to him he has appealed.

Henry B. Peacock, Jr., who will be called the taxpayer, and his mother, owned a dwelling in Miami, Florida, which they occupied as a residence. They organized Fidelis Corporation, the...

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