Legal Opinion

Commissioner of Internal Revenue v. Hammel

Court of Appeals for the Sixth Circuit

Decided January 10, 1940No. 8043PublishedCited by 14 opinions

1Opinion of the Court

HAMILTON, Circuit Judge.

This is a petition by the Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals disallowing a deficiency in income taxes of $426 for the calendar year 1934, found by him to be due from the respondents, but disallowed by the Board.

The statutes involved are Sections 23(e) (2), 26 U.S.C.A. § 23(e) (2), Section 111 (a) , 26 U.S.C.A. § 111(a), Section 117(a) (b) (d), 26 U.S.C.A. § 101 (a, b, d).

During the years 1926 to 1930, both inclusive, the respondents, Godfrey Hammel and Pearl Hammel, husband and wife, paid $4,998.03 into a syndicate of…

2Cases cited8 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  3. Williamson v. BerrySupreme Court of the United States · 1850
  4. Hale v. HelveringCourt of Appeals for the D.C. Circuit · 1936
  5. Butler v. ThomsonSupreme Court of the United States · 1876

3 more not listed; retrieve them via the Exa API.

3Cited by14 opinions

  1. Helvering v. HammelSupreme Court of the United States · 1941
  2. Freeland v. CommissionerUnited States Tax Court · 1980
  3. Commissioner of Internal Revenue v. PetermanCourt of Appeals for the Ninth Circuit · 1941
  4. Helvering v. Nebraska Bridge Supply & Lumber Co.Court of Appeals for the Eighth Circuit · 1940
  5. CL Gransden & Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1941

9 more not listed; retrieve them via the Exa API.

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