Legal Opinion · Dissent
C.J.D. Rudolph and Irma M. Rudolph v. United States
Court of Appeals for the Fifth Circuit
Decided July 28, 1961No. 18788_1Published
1DissentJohn R. Brown, Circuit Judge
To what was urged by my dissent in Patterson v. Thomas, 5 Cir., 1961, 289 F.2d 108, at page 114. I would add brief comments on a few matters bearing emphasis in this record.
The notion that this was one big happy company-paid-for-holiday in New York City where a formal session for the first half day was a mere tip-of-the-hat to give appearances of a working trip is simply unfounded. Mr. Rudolph, the Taxpayer, and his wife — a companion, coworker, partner-in-fact in the business of life insurance business as well as fellow Taxpayer — had nothing to do with selecting the time, the place, or the…
2Cases cited17 opinions
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- A. Finkenberg's Sons, Inc. v. CommissionerUnited States Tax Court · 1951
- George D. Patterson, District Director of Internal Revenue v. J. C. Thomas and Martha ThomasCourt of Appeals for the Fifth Circuit · 1961
- Pacific Grape Products Co., a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- State Ex Rel. State Public Welfare Commission v. County Court of Malheur CountyOregon Supreme Court · 1949
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