I. W. Thompson, Individually and Wife, Charlie Thompson v. United States

JOHN R. BROWN, Circuit Judge.

I. W. Thompson, his wife Charlie Thompson, and I. W. Thompson, as Trustee for Selected Minority Funds1 sued in the District Court to recover income taxes, penalties, and interest in the aggregate amount of $171,665.65, assessed against the Thompsons for the years 1952-1956 and collected by levy on the bank accounts of the Thompsons and Selected.2

On September 19, 1949, I. W. Thompson, referring to himself as Donor and naming himself as Trustee, executed an instrument establishing Selected. Subsequently the Thompsons executed a deed conveying to I. W. Thompson,…