From Casetext: Smarter Legal Research

Brown v. Commissioner of Internal Revenue

Circuit Court of Appeals, Fifth Circuit
Feb 22, 1932
55 F.2d 1076 (5th Cir. 1932)

Opinion

No. 6187.

February 22, 1932.

Petition for Review of Decision of the United States Board of Tax Appeals, District of Georgia.

J.C. Murphy, of Atlanta, Ga., for petitioner.

G.A. Youngquist, Asst. Atty. Gen., Sewall Key and Wm. Cutler Thompson, Sp. Assts. to Atty. Gen., and C.M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Allin H. Pierce, Sp. Atty. Bureau of Internal Revenue, both of Washington, D.C., for respondent.

Before BRYAN, FOSTER, and WALKER, Circuit Judges.


The Board of Tax Appeals held the petitioner liable for an income tax upon the amounts of compensation he received from the city of Atlanta as supervising architect for a number of public school buildings.

The facts are fully stated in the opinion of the Board, reported in 19 B.T.A. 568, and need not be repeated here. We think the case is controlled by the decision of the Supreme Court in Metcalf Eddy v. Mitchell, 269 U.S. 514, 46 S. Ct. 172, 70 L. Ed. 384.

The petition for review is denied.


Summaries of

Brown v. Commissioner of Internal Revenue

Circuit Court of Appeals, Fifth Circuit
Feb 22, 1932
55 F.2d 1076 (5th Cir. 1932)
Case details for

Brown v. Commissioner of Internal Revenue

Case Details

Full title:A. Ten Eyck BROWN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE…

Court:Circuit Court of Appeals, Fifth Circuit

Date published: Feb 22, 1932

Citations

55 F.2d 1076 (5th Cir. 1932)

Citing Cases

Kirby v. Department of Revenue

The two cases and plaintiffs' arguments are applicable (1) to completed exchanges of property where at the…

Consoer, Older & Quinlan, Inc. v. Commissioner

While we are not prepared to hold that employment must be continuous and that it cannot be limited to…