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RICHARDS v. COMMISSIONER OF INTERNAL REVENUE

No. 14644.

213 F.2d 494 (1954)

RICHARDS et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

May 26, 1954.

Attorney(s) appearing for the Case

Gibbons Burke, New Orleans, La., for petitioner.

Carolyn R. Just, Sp. Asst. to Atty. Gen., Ellis N. Slack, Asst. Atty. Gen., L. W. Post, Asst. Atty. Gen., H. Brian Holland, Asst. Atty. Gen., Kenneth W. Gemmill, Acting Chief Counsel, Internal Revenue Service, Charles E. Lowery, Sp. Atty., for respondent.

Before HUTCHESON, Chief Judge, and HOLMES and RIVES, Circuit Judges.

RIVES, Circuit Judge.

The single question presented for review is whether [under Section 22(a) of the Internal Revenue Code, 26 U.S. C.A., as interpreted in Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788] the Tax Court correctly held that the taxpayers are accountable for the dividends on certain shares of stock to which they retained the legal title although an interest in...

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