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MOUGHON v. C. I. R.

Nos. 15428-15430.

329 F.2d 399 (1964)

Morris MOUGHON and Wife, Virginia Moughon, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. MARTIN A. HAYES & CO., Inc., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Hubert C. CUNNINGHAM, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

Decided March 27, 1964.

Attorney(s) appearing for the Case

Richard H. Frank, Jr., and John M. Barksdale, Nashville, Tenn., for petitioners.

Fred R. Becker, Dept. of Justice, Washington, D. C., for respondent; Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Attys., Dept. of Justice, Washington, D. C., on brief.

Before CECIL and PHILLIPS, Circuit Judges, and PECK, District Judge.

PECK, District Judge.

These cases, which were consolidated for presentation in this court, arose from the issuance of deficiency notices by the appellee against the taxpayer appellants. In these notices, appellee determined that all three taxpayers (a fourth is a party to case No. 15428 solely because she participated in a joint return) were liable for additional income taxes for the calendar years 1956, 1957 and 1958.

The record discloses that in 1945 Moughon...

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