CARPENTER v. C. I. R.

No. 13124.

415 F.2d 806 (1969)

C. Clinton CARPENTER and Phyllis S. Carpenter, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals Fourth Circuit.

Decided September 16, 1969.


Attorney(s) appearing for the Case

Richard B. Spindle, III, Norfolk, Va., for petitioners.

Issie L. Jenkins, Atty., Department of Justice (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Elmer J. Kelsey, Attys., Department of Justice, on the brief), for respondent.

Before BOREMAN, BRYAN and BUTZNER, Circuit Judges.


PER CURIAM:

The Carpenters appeal from a decision of the Tax Court upholding an assessment against them by the Commissioner of Internal Revenue of an income tax deficiency for the taxable year 1957 in the amount of $39,687.41.

The facts, some of which were stipulated, were found and stated in the Tax Court's opinion substantially as follows:1

Mr. Carpenter was engaged in the construction business from 1920. Prior to and...

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