Jack L. Easson, June B. Easson, and Envoy Apartments v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Jack L. Easson, June B. Easson, and Envoy Apartments

294 F.2d 653 Jack L. EASSON, June B. Easson, and Envoy Apartments, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Jack L. EASSON, June B. Easson, and Envoy Apartments, Respondents. No. 17170. United States Court of Appeals Ninth Circuit. September 8, 1961. Nathan L. Cohen, Ralph R. Bailey and Maguire, Shields, Morrison, Bailey & Kester, Portland, Or., for petitioner. Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney, Kenneth E. Levin, Dept. of Justice, Washington, D. C., for respondent. Before ORR, BARNES and MERRILL, Circuit Judges. BARNES, Circuit Judge. 1 The Tax Court had jurisdiction to hear taxpayer's 1 petition to redetermine a deficiency asserted by the Commissioner (§ 272(a) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 272 (a)). This court has jurisdiction on appeal (§ 7482, Internal Revenue Code of 1954, 26 U.S.C.A. § 7482 ). 2 In 1952 taxpayer owned and operated an apartment house in Portland, Oregon. On June 19, 1952, taxpayer encumbered the apartment house with a $250,000 mortgage, taxpayer himself signing and assuming personal liability on the notes…