Helga Carlen v. Commissioner Of Internal Revenue

220 F.2d 338 Helga CARLEN, John T. Carlen, Cathryn McKay, Arthur R. McKay, Arthur R. and Cathryn McKay and John T. and Helga Carlen, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 14090. United States Court of Appeals, Ninth Circuit. March 14, 1955. Charles F. Osborn, Seattle, Wash., Lester T. Parker, Aberdeen, Wash., for petitioners. H. Brian Holland, Asst. Atty. Gen., Karl Schmeidler, Ellis N. Slack, Hilbert P. Zarky, Meyer Rothwacks, Sp. Assts. to Atty. Gen., Kenneth W. Gemmill, Acting Chief Counsel, I. R. S., Washington, D. C., for respondent. Before BONE and CHAMBERS, Circuit Judges and CLARK, District Judge. BONE, Circuit Judge. 1 This case comes to us for review of a decision of the Tax Court. 1 The income taxes here involved are for the tax years 1947, 1948, 1949 and 1950. 2 Reference should be had to the opinion and findings of the Tax Court which fully outline the pertinent and basic facts in the instant case and provide a clear picture of the problem before this Court. The parties stipulated (among other matters) to certain facts which were also found by the Tax Court and included in its findings by reference thereto. In this stipulation of facts the…