United States v. Mrs. Edna Britt

POPE, Circuit Judge.

This case involves a dispute over the taxability as income of certain funds involved in small loan transactions in Mississippi. A deficiency letter had been issued to taxpayer, the deceased husband of plaintiff Edna Britt, and he had paid the deficiency. His widow sues to recover that amount.

The small loan business in Mississippi is regulated by the Small Loan Regulatory Act, Miss.Laws (1958), c. 170; 4A Miss.Laws Anno. Sec. 5591-01 et seq. (1962 Supp.). Three parties are involved in small loan transactions: the borrower; the broker, who arranged and guarantees the loan;…