Porter v. Commissioner

WOOLLEY, Circuit Judge.

This case differs from that of Houston v. Commissioner (C. C. A.) 39 F.(2d) 351, mainly in procedure and in one issue of law arising from the procedure.

William W. Porter was one of the eleven directors of the Real Estate Trust Company of Philadelphia who, on its failure in 1906, raised among themselves a fund of $2,505,000 to restore its solvency. His epntribution was $75,000. The fund was to be used for the purpose and be returned to the contributors as set forth at length in Houston v. Commissioner, supra. The Trust Company closed out the matter in 1920 and in…