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C. I. R. v. KELLEY

No. 18185.

293 F.2d 904 (1961)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. James B. KELLEY and Lena S. Kelley, and John Waltman and Doris Waltman, Respondents.

United States Court of Appeals Fifth Circuit.

August 2, 1961.

Attorney(s) appearing for the Case

David O. Walter, Harry Baum, Lee A. Jackson, Dept. of Justice, Washington, D. C., Claude R. Marshall, Sp. Atty., I. R. S., Hart H. Spiegel, Chief Counsel, I. R. S., Washington, D. C., Charles K. Rice, Asst. Atty. Gen., for petitioner.

William R. Frazier, Jacksonville, Fla., Hill & Frazier, James P. Hill, Jacksonville, Fla., for respondents.

Before TUTTLE, Chief Judge, and RIVES and WISDOM, Circuit Judges.

WISDOM, Circuit Judge.

The tax definition of a "collapsible corporation" illustrates again that the "difficulties of so-called interpretation arise when the legislature had no meaning at all; when the question which is raised on the statute never occurred to" the legislature.1 In the matter now before us our difficulties come from the certainty of the general congressional purpose in enacting Section 117(m) of the Internal Revenue Code...

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