Ingram v. Bowers

L. HAND, Circuit Judge.

The plaintiff is the widow and ancillary administratrix of the singer, Caruso, who during his life paid the sums at issue in discharge of deficiency assessments of income taxes for the years, 1918,1919 and 1920. She sued to recover these; the ease was tried before a jury of one, and the judge directed a verdict for the defendant at the end of the evidence and wrote an opinion stating the facts in detail. Ingram v. Bowers (D. C.) 47 F.(2d) 925. We adopt his statement, and refer to it as the premise of our discussion.

The case turns upon the moaning of the phrase, “gross…