C. I. R. v. MINZER

No. 18084.

279 F.2d 338 (1960)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Sol MINZER and Adele Minzer, Respondents.

United States Court of Appeals Fifth Circuit.

June 3, 1960.


Attorney(s) appearing for the Case

Hart H. Spiegel, Chief Counsel, I.R.S., Charles Owen Johnson, Sp. Atty., I.R.S., Washington, D. C., Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, I. Henry Kutz, Carolyn R. Just, Atty., Dept. of Justice, Washington, D. C., for petitioner.

Samuel E. Ziegler, Dallas, Tex., Carlyle M. Dunaway, Washington, D. C., General Counsel, National Ass'n of Life Underwriters, of counsel, for respondents.

Before TUTTLE, CAMERON and JONES, Circuit Judges.


JONES, Circuit Judge.

We are here concerned with the liability of Sol Minzer and Adele Minzer, his wife, for a federal income tax deficiency for the year 1954. The transactions from which the controversy stems were those of Sol Minzer and he will be referred to as the taxpayer. No issues of fact are presented.

In 1954 the taxpayer was an insurance agent or broker. During that year he procured or kept in force policies of insurance upon his life. As a representative...

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