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MERCER v. C. I. R.

No. 21239.

376 F.2d 708 (1967)

Loy D. MERCER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

April 17, 1967.

Attorney(s) appearing for the Case

Courtney Vallentine, Albuquerque, N. M., for appellant.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Marco S. Sonnenschein, Attys., Lester Uretz, Chief Counsel, Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before BARNES and JERTBERG, Circuit Judges, and HALBERT, District Judge.

BARNES, Circuit Judge.

This is a petition to review a decision of the Tax Court of the United States. That Court had jurisdiction of the case. (26 U.S.C. § 6213.) We have jurisdiction of the petition for review under 26 U.S.C. § 7482.

Petitioner Loy Mercer and his older brother Berle were raised on a cattle ranch in Nebraska, where they learned the rudiments of the cattle business. In 1957 Berle moved to Alaska with his family and a herd of cattle...

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