V. Zay Smith, and Ida Smith v. Commissioner of Internal Revenue

HILL, Circuit Judge.

This case is here on the Smiths’ Petition To Review a decision of the Tax Court of the United States which was adverse to them. 1

The facts necessary for our disposition of the case are not in dispute. In January, 1947, Y. Zay Smith (petitioner) and three other individuals formed a partnership known,as Geophoto Services (Geophoto) for the purpose of engaging in the business of evaluating geological structures based upon aerial photography, which was to be used in the search for petroleum and petroleum reserves. Petitioner, at the time of World War II, was a geologist and,…