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HILLARD v. C. I. R.

No. 17915.

281 F.2d 279 (1960)

Charlie HILLARD and Mary Jane Hillard, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

August 5, 1960.

Attorney(s) appearing for the Case

Geo. S. Atkinson, Tom B. Rhodes, Dallas, Tex., Ellis Lyons, Washington, D. C., for petitioners.

Meyer Rothwacks, Lee A. Jackson, Rita E. Hauser, Melva M. Graney, Attys., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., Arch M. Cantrall, Chief Counsel, John M. Morawski, Sp. Atty., I.R.S., Washington, D. C., for respondent. Perlman, Lyons & Emmerglick, Washington, D. C., Jess S. Raban, Chicago, Ill., of counsel.

Before JONES, BROWN and WISDOM, Circuit Judges.

JONES, Circuit Judge.

The petitioners, Charlie Hillard and Mary Jane Hillard, husband and wife, ask us to review and reverse a decision of the Tax Court adverse to them. Hillard v. Commissioner, 31 T.C. 961. The Petitioner Charlie Hillard, who will generally be called the taxpayer, lived in Fort Worth, Texas. There he operated three businesses; he operated (1) a car and truck rental business under the name of Hillard's Rent-A-Car, ...

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