Gawler v. Commissioner of Internal Revenue

Full title: JOHN P. GAWLER AND ANNABEL C. GAWLER, APPELLANTS v. COMMISSIONER OF…

Court: United States Court of Appeals, Fourth Circuit

Date published: Oct 18, 1974

504 F.2d 425 (4th Cir. 1974)

Opinion

Nos. 74-1185 to 74-1190.

Argued October 2, 1974.

Decided October 18, 1974.

Bruce R. Hopkins, Washington, D.C. (Williams, Myers Quiggle, Washington, D.C., on brief) for appellants.

Alfred S. Lombardi, Atty., Tax Div., U.S. Dept. of Justice (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks and Jonathan S. Cohen, Attys., Tax Div., U.S. Dept. of Justice, on brief), for appellee.

Appeal from the United States Tax Court, at Washington, D.C.; Theodore Tannenwald, Jr., Judge.

Before BOREMAN, Senior Circuit Judge and WINTER and CRAVEN, Circuit Judges.

PER CURIAM:

Judge Winter and Judge Craven agree that the judgment of the tax court should be affirmed for the reasons set forth in the opinion of Judge Tannenwald, writing for the majority in Gawler v. Commissioner, 60 T.C. 647 (1973); while Judge Boreman would reverse for the reasons set forth by Judge Drennen, dissenting in that case.

Affirmed.