John D. And Janice L. Edwards v. Commissioner of Internal Revenue

BARNES, Circuit Judge.

This appeal involves an alleged deficiency in taxpayers’ income tax for 1955. The decision of the Tax Court was adverse to petitioners. (39 T.C. No. 8.) Jurisdiction exists pursuant to Section 7482 of the Internal Revenue Code of 1954.

Two questions are raised:

I

In 1955 taxpayer husband received $13,-027.21 from his employer in settlement of two judgments totaling $15,155.00 obtained for bonuses claimed. In computing the settlement, there was no deduction made for withholding taxes, and there had been no discussion between the parties concerning it. The employer, in fact,…