LLEWELLYN v. C. I. R.

No. 13293.

295 F.2d 649 (1961)

Maxwell B. LLEWELLYN and Gertrude Llewellyn, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

November 7, 1961.


Attorney(s) appearing for the Case

Hiram M. Nowlan, Janesville, Wis., for petitioner.

Lee A. Jackson, Chief, Appellate Section, Harold M. Seidel, Attorney, U. S. Department of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Robert N. Anderson, Attorney, Department of Justice, Washington, D. C., for respondent.

Before HASTINGS, Chief Judge, and SCHNACKENBERG and KNOCH, Circuit Judges.


KNOCH, Circuit Judge.

The petitioners, Maxwell B. Llewellyn and Gertrude Llewellyn, his wife, seek review of the Tax Court's decision sustaining the Commissioner's determination of deficiencies and additions respecting petitioners' income taxes for the years 1953 and 1954. Mrs. Llewellyn is a party only because she and her husband filed joint returns.

Dr. Maxwell B. Llewellyn entered into written agreements (which were in effect during the taxable years in...

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