Doyle v. Commissioner of Internal Revenue

DOBIE, Circuit Judge.

This is a petition of Richard S. Doyle to review a decision of the Tax Court of the United States, adverse to Doyle, determining Doyle’s income tax for the calendar year 1938. The opinion of the Tax Court is reported in 3 T. C. 1092. We first attempt a brief summary of the rather complicated facts in this case and then discuss the single question of law raised by these facts.

On December 11, 1919, Briggs and Turivas (an Illinois corporation, hereinafter called Briggs) entered into a contract with the United States Shipping Board (an agency of the United States, hereinafter…