Lougee v. Commissioner

BINGHAM, Circuit Judge.

This is a petition to revise a decision of the Board of Tax Appeals sustaining a deficiency tax of $1,136.23 assessed against the petitioner upon $16,000, which he failed to return as income for the year 1926.

The Board of Tax Appeals found as a fact that the $16,000 was received by the petitioner in 1926 as additional compensation for past services in the nature of salary and was taxable income. The petitioner’s *113contention is that the $16,000 was paid to and received by him as a gift.

As the scope of review by this court of decisions of the Board of Tax Appeals is…