United States v. Harry Schroeder, Amanda Schroeder, Richard Schroeder and Jacqueline l.schroeder

MATTHES, Circuit Judge.

The issue in this case is whether three tracts of Iowa farm land are owned by Harry Schroeder and should be subjected to the payment of delinquent federal taxes. The district court found that such property belonged to Richard Schroeder, Harry’s son, and dismissed the Government’s cause of action as to this phase of the case. From this judgment the Government has appealed. We affirm.

The pertinent background facts have been established by administrative and judicial proceedings and are, of course, not in dispute.

By letter dated July 3, 1951, the Commissioner of Internal…