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GALLUN v. C. I. R.

Nos. 13341, 13342.

297 F.2d 455 (1961)

Edwin A. GALLUN and Jane W. Gallun, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. A. F. GALLUN & SONS CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

December 13, 1961.

Attorney(s) appearing for the Case

Richard S. Gibbs and W. J. Roper, Milwaukee, Wis., Burlingame, Gibbs & Roper, Milwaukee, Wis., of counsel, for petitioners.

Lee A. Jackson, Chief, Appellate Section, Gilbert E. Andrews, Jr., Attorney, U. S. Department of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks, Attorney, Department of Justice, Washington, D. C., for respondent.

Before SCHNACKENBERG, KNOCH and KILEY, Circuit Judges.

KNOCH, Circuit Judge.

The petitioners in these consolidated cases seek review of deficiencies determined by the Tax Court of the United States, in the amount of $28,401.44 for the calendar year 1954 for Edwin A. and Jane W. Gallun, and in the amount of $17,382.09 for the fiscal year ending September 30, 1954, for A. F. Gallun & Sons Corporation.

The deficiencies claimed in these cases arise out of disallowances of deductions made by petitioners for "bond...

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