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PFLUGRADT v. UNITED STATES

Nos. 13761-13764.

310 F.2d 412 (1962)

Allen PFLUGRADT and Ethel Pflugradt, his wife, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. John Roggenbauer MOELLER, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. James W. PFLUGRADT and Lillian Pflugradt, his wife, Plaintiffs-Appellants. v. UNITED STATES of America, Defendant-Appellee. Jane WOLFE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Seventh Circuit.

December 4, 1962.

Attorney(s) appearing for the Case

Thomas F. Carroll, Richard H. Lauritzen, Milwaukee, Wis., for appellants.

Louis F. Oberdorfer, Asst. Atty. Gen., Arthur E. Strout, Atty., Tax Division, U. S. Dept. of Justice, Washington, D. C.

James B. Brennan, U. S. Atty., Milwaukee, Wis., John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., for appellee.

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

HASTINGS, Chief Judge.

These four proceedings are before us on appeals by taxpayers for review of a judgment of the district court dismissing their respective suits for refunds of taxes paid pursuant to deficiency assessments.1

The basis for the deficiency assessments was the Commissioner's determination that certain minor children were not the owners of limited partnership interests under...

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