BOE v. C. I. R.

No. 17562.

307 F.2d 339 (1962)

Richard M. BOE and Mary Lots Boe, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

August 21, 1962.


Attorney(s) appearing for the Case

W. Lee McLane, Jr., Nola McLane, and Thaddeus Rojek, Phoenix, Ariz., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum and Burt J. Abrams, Morton K. Rothschild, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before CHAMBERS and DUNIWAY, Circuit Judges, JAMESON, District Judge.


DUNIWAY, Circuit Judge.

Petition to review a decision of the Tax Court. The facts are not in dispute; the argument concerns their legal effect. We conclude that the decision of the Tax Court is correct. For convenience, we refer to petitioners, husband and wife, as "taxpayer".

Deficiencies in personal income tax for the years 1952, 1953 and 1954 are involved. They arise from the purchase of the medical practice of F. W. Callison, M.D., who conducted a group...

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