Richard Beatty v. Frank M. Halpin, Former Director of Internal Revenue

GARDNER, Chief Judge.

During the years involved in this case appellant was the owner of a number of apartment houses in and around the city of Des Moines, Iowa. These properties were cared for by persons living in them who received in return for their services all or part of the rent of the apartments which they occupied. On the theory that these caretakers were employees of appellant, the then Director of Internal Revenue assessed against appellant Federal Unemployment Tax Act taxes for the period 1946 through 1955 and Federal Insurance Contributions Act taxes for the period October 1, 1949…