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MORGAN v. COMMISSIONER OF INTERNAL REVENUE

No. 15898.

277 F.2d 152 (1960)

Arthur V. MORGAN and Dorothy O. Morgan, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

March 15, 1960.

Attorney(s) appearing for the Case

Leonard B. Hankins, Long Beach, Cal., for petitioners.

Thomas T. Files, Felix S. Wahrhaftig, Sacramento, Cal., amicus curii.

Charles K. Rice, Asst. Atty. Gen., Carolyn R. Just, Lee A. Jackson, Meyer Rothwacks, Attorneys, Dept. of Justice, Washington, D. C., for respondent.

Before CHAMBERS, BARNES and KOELSCH, Circuit Judges.

PER CURIAM.

This is an appeal from the Tax Court (26 U.S.C. § 7482) where the determination of a deficiency made by the Commissioner of Internal Revenue for 1950 was upheld on review (Int.Rev.Code of 1939, § 272, 26 U.S.C.A. § 272).

Taxpayer Arthur V. Morgan was a member of a partnership engaged in the used car business which kept its books on an accrual basis and sold large numbers of cars under conditional sales contracts. These contracts...

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