Pohlen v. Commissioner

HOLMES, Circuit Judge.

This appeal involves income taxes and penalties for the year 1943. The year 1942 is also involved because of the pay-as-you-go provisions of the Act of 1943, 26 U.S. C.A. Int.Rev.Code, §§ 1621-1627. William F. Pohlen (hereinafter referred to as the taxpayer) and his wife are residents of San Antonio, Texas. They filed joint income-tax returns for 1942, and separate returns for 1943, on which each reported one-half of their community income.

For many years, the taxpayer has been engaged in soliciting funds for various charities. He entered into a contract, dated May 14,…