v2414-1005

In the United States Court of Appeals

for the Ninth District

No. 11070

Byron C. Hanna, petitioner

Commissioner of Internal Revenue, respondent

No. 11071

Daisy May Hanna, petitioner

Commissioner of Internal Revenue, respondent

ON PETITIONS FOR REVIEW OF THE DECISIONS OF

THE TAX COURT OF THE UNITED STATES

BRIEF FOR THE RESPONDENT

OPINION BELOW

The memorandum findings of fact and opinion of the

Tax Court (R. 22-27)^ are unreported.

jurisdiction

These consolidated petitions for review involve income

tax deficiencies for 1940 determined against Byron C.

^ All record references, unless otherwise indicated, are to the

complete record in No. 11071.

(1)

---

archive.org Volume Name: govuscourtsca9briefs2414

Volume: http://archive.org/stream/govuscourtsca9briefs2414

Document Link: http://archive.org/stream/govuscourtsca9briefs2414#page/n1004/mode/1up

Top Keywords (auto-generated):

tax, hanna, compensation, services, morton, 27, income, 107, taxpayers, section, expenses, 1940, commissioner, partnership, paid

Top Key Phrases (auto-generated):

section 107, internal revenue, 95 percent, revenue code, income tax, services rendered, special method, future expenses, american oil, accumulated interest, tax returns, partner ship, avail themselves, withdrawals totaling, unrestrictedly available

Document Status: UGLY