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SOVEREIGN v. C. I. R.

No. 12939.

281 F.2d 830 (1960)

E. R. SOVEREIGN and Phyllis Sovereign, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

August 2, 1960.

Attorney(s) appearing for the Case

Louis L. Meldman, Sherwin C. Peltin, Milwaukee, Wis., for petitioners.

Charles K. Rice, Asst. Atty. Gen., Tax Division, Louise Foster, Atty., U. S. Dept. of Justice, Washington, D. C., for respondent.

Before SCHNACKENBERG, KNOCH and CASTLE, Circuit Judges.

KNOCH, Circuit Judge.

E. R. Sovereign and Phyllis Sovereign, his wife, have appealed decisions of the Tax Court sustaining deficiencies in income tax assessed against them. Appellants list errors alleged to arise out of failure to apply the law correctly, reliance on a theory raised by neither party, failure to allow additional hearing and presentation of evidence on that theory, and failure to base the decisions on the facts of record.

E. R. Sovereign was...

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