Maxwell B. Llewellyn and Gertrude Llewellyn v. Commissioner of Internal Revenue

ENOCH, Circuit Judge.

The petitioners, Maxwell B. Llewellyn and Gertrude Llewellyn, his wife, seek review of the Tax Court’s decision sustaining the Commissioner’s determination of' deficiencies and additions respecting petitioners’ income taxes for the years 1953 and 1954. Mrs. Llewellyn is a party only because she and her husband filed joint returns.

Dr. Maxwell B. Llewellyn entered into written agreements (which were in effect during the taxable years in question) with Fort Atkinson Hospital, Fort Atkinson, Wisconsin, and Mercy Hospital, Janesville, Wisconsin, to perform services for these…