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BROWN v. C. I. R.

No. 682-70.

448 F.2d 514 (1971)

Royce W. BROWN and Patty L. Brown, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

September 14, 1971.

Attorney(s) appearing for the Case

Charles B. Lutz, Jr., Oklahoma City, Okl. (John K. Speck, Oklahoma City, Okl., on the brief), for appellants.

Wesley J. Filer, Atty., Tax Division, Department of Justice, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks and William Massar, Washington, D. C., on the brief), for appellee.

Before HILL, McWILLIAMS and BARRETT, Circuit Judges.

HILL, Circuit Judge.

This is an appeal from a decision of the Tax Court of the United States1 wherein that court upheld tax deficiencies in the amount of $19,405.46 assessed against taxpayer for the taxable year 1963.

Petitioners-appellants are husband and wife. Patty L. Brown executed the 1963 joint Federal Income Tax Return involved, as wife of Royce W. Brown, but took no active part in the business involved. We will be speaking...

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