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CANADAY v. GUITTEAU

Nos. 7058, 7059.

86 F.2d 303 (1936)

CANADAY v. GUITTEAU, Collector of Internal Revenue.

Circuit Court of Appeals, Sixth Circuit.

November 13, 1936.

Attorney(s) appearing for the Case

George W. Ritter, of Toledo, Ohio, for appellant.

William B. Waldo, of Washington, D. C. (Frank J. Wideman, J. Louis Monarch, and J. Leonard Lyons, all of Washington, D. C., Emerich B. Freed, of Cleveland, Ohio, Gerald B. Openlander, of Toledo, Ohio, and William B. Waldo, of Washington, D. C., on the brief), for appellee.

Before HICKS and SIMONS, Circuit Judges, and FORD, District Judge.

FORD, District Judge.

This appeal is from a judgment dismissing appellant's petition by which he sought to recover certain federal income taxes paid for the years 1927, 1928, and 1929, on account of deficiency assessments by which certain premiums on appellant's life insurance policies paid during those years by the United States Advertising Corporation, of which he was president and a large stockholder, were treated as income to him and so taxed.

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