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EVANS v. COMMISSIONER OF INTERNAL REVENUE

No. 22509.

413 F.2d 1047 (1969)

Frank J. EVANS and Margueritte A. Evans, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

July 7, 1969.

Attorney(s) appearing for the Case

Martin J. May (argued), of Noland, Hamerly, Etienne & Fulton, Salinas, Cal., for appellants.

Carolyn R. Just (argued), Mitchell Rogovin, Asst. Atty. Gen., Meyer Rothwacks, Crombie J. D. Garrett, Attys., Dept. of Justice, Washington, D. C., for appellee.

Before HAMLEY, HAMLIN, and ELY, Circuit Judges.

PER CURIAM:

The taxpayers purchased a trailer park and subsequently operated it. Stipulated portions of the purchase price represented the cost of four utility systems which had been installed for sewage disposal and for the distribution of electricity, gas, and water to those who rented space in the facility. The issue presented is whether the taxpayers are entitled to an investment credit (under sections 38, 46, and 48 of the Internal Revenue Code of 1954) for the...

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