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BERTHOLD v. C. I. R.

No. 18289.

404 F.2d 119 (1968)

Paul W. BERTHOLD and Dorothy Berthold, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

Decided November 26, 1968.

Attorney(s) appearing for the Case

Paul A. Weick, Akron, Ohio, for petitioners.

Bennet N. Hollander, Dept. of Justice, Washington, D. C., for respondent; Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, William A. Friedlander, Attys., Dept. of Justice, Washington, D. C., on brief.

Before O'SULLIVAN, PHILLIPS and EDWARDS, Circuit Judges.

EDWARDS, Circuit Judge.

This is an appeal from a decision of the Tax Court adverse to the taxpayers. Petitioners are husband and wife who filed joint tax returns for the years 1957, 1958, and 1959 wherein this dispute arose. During all the applicable times Paul Berthold was owner and in sole control of two corporations — the Berthold Electric Company1 and the Walberton Company.

The tax dispute pertains to the handling of...

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