Gerald M. Friend v. United States

HARTIGAN, Senior Circuit Judge (by designation).

This is an appeal from a judgment of the United States District Court for the District of Massachusetts, entered March 4, 1964, for the defendant in a suit to recover $7,846.58 (together with interest) paid in federal income taxes for the year 1954.

The basic facts are not disputed. In 1954’ Gerald M. Friend, the taxpayer, was controlling stockholder in Gerald M. Friend, Inc., a Massachusetts corporation doing business in the years 1954 and following as a jobber of ladies’ blouses and accessories. In 1954, just prior to the events pertinent to…