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CHAMPION v. C. I. R.

No. 18937.

303 F.2d 887 (1962)

Flora L. CHAMPION, Individually and as Independent Executrix of the Estate of Frank Champion, deceased, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

June 11, 1962.

Attorney(s) appearing for the Case

Dougal C. Pope, Charles Crady, III, Houston, Tex., for petitioner.

R. P. Hertzog, Acting Chief Counsel, I. R. S., Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, A. F. Prescott, Carolyn R. Just, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before TUTTLE, Chief Judge, and HUTCHESON and JONES, Circuit Judges.

JONES, Circuit Judge.

The Commissioner of Internal Revenue determined income tax deficiencies of Frank Champion and Flora L. Champion for the year 1951 in the amount of $3,358.94, and for the year 1952 in the amount of $177,096.56. The Tax Court agreed with the Commissioner's determination, and its decision and order is before us for review. The transactions from which the asserted tax deficiency arose were those of Frank Champion, who was a party in the proceeding...

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