Ione Thomson, Cynthia Farver, Walter Thomson, Trustees for Dissolved Aero Sales Co. v. Commissioner of Internal Revenue, Walter Thomson and Ione Thomson v. Commissioner of Internal Revenue

406 F.2d 1006 Ione THOMSON, Cynthia Farver, Walter Thomson, Trustees for dissolved Aero Sales Co., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Walter THOMSON and Ione Thomson, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 22109. No. 22109-A. United States Court of Appeals Ninth Circuit. January 23, 1969. Walter Thomson, (argued), Los Angeles, Cal., for appellant. Edward L. Rogers, Washington, D. C., (argued), Mitchell Rogovin, Asst. Atty. Gen., Tax Div., Lester R. Uretz, Chief Counsel, Lee A. Jackson, David O. Walter, Attys., Washington, D. C., for appellees. Before CHAMBERS and ELY, Circuit Judges, and THOMPSON, * District Judge. ELY, Circuit Judge: 1 This is a petition to review Tax Court decisions 1 allocating the entire amount received by petitioners in a compromise settlement of a civil action against the United States to ordinary income and allocating also to ordinary income five-sixths of an amount petitioners received in settlement of an antitrust suit. Our jurisdiction rests on Section 7482 of the Internal Revenue Code of 1954. We affirm. 2 Petitioners Thomson are husband and wife. They operated the Texas Tank Company as a…