386 F2d 450 Mears v. Commissioner of Internal Revenue
386 F.2d 450
Raymond J. MEARS, a/k/a R. J. Mears et al., Petitioners,
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fifth Circuit.
November 29, 1967.
Petition for Review of a Decision of the Tax Court of the United States (Florida Case).
Benjamin S. Schwartz, Richard B. Wallace, Miami, Fla., for petitioners.
Lester R. Uretz, Chief Counsel, IRS, Charles Owen Johnson, Atty., IRS, Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Harry Marselli, Robert N. Anderson, Chester C. Davenport, Attys., Dept. of Justice, Washington, D. C., for respondent.
Before JONES, WISDOM and DYER, Circuit Judges.
This appeal tests the correctness of a memorandum decision of the Tax Court finding liability of the petitioner for income tax deficiencies. Mears v. Commissioner, Par. 66173, P-H T.C. The applicable rules of law were correctly stated and applied by the Tax Court in reaching its conclusion. Its decision is