Thomas P. Pike and Katherine Keho Pike v. United States

231 F.2d 688 56-1 USTC P 9308 Thomas P. PIKE and Katherine Keho Pike, Appellants, v. UNITED STATES of America, Appellee. No. 14102. United States Court of Appeals Ninth Circuit. Feb. 16, 1956. Mackay, McGregor, Reynolds & Bennion, Los Angeles, Cal., for appellants. H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Robert B. Ross, Sp. Assts. to Atty. Gen., Laughlin E. Waters, U.S. Atty., Edward R. McHale, Eugene Harpole, Asst. U.S. Attys., Los Angeles, Cal., Walter Akerman, Jr., Tax Division, Department of Justice, Washington, D.C., for appellee. Before POPE, FEE and CHAMBERS, Circuit Judges. POPE, Circuit Judge. 1 On February 8, 1944, the appellants with others, formed a partnership known as 'Pike and Associates' which carried on business until dissolved on February 15, 1946. On August 31, 1944, a second partnership known as 'Thomas P. Pike, Operator' was formed by the appellants and others which was still in existence at the time of the trial of this cause in the district court. Each of these partnerships made income tax returns for their respective fiscal years ending in 1945, 1946 and 1947. Each return showed the income of the respective partnerships to be distributable…