Wagner v. Commissioner

SAWTELLE, Circuit Judge.

This is an appeal from a decision of the United States Board of Tax Appeals affirming the action of the Commissioner of Internal Revenue in determining that there is a deficiency of $13,380.44 in the decedent’s income tax for 1930.

A summary of the board’s findings of fact follows: In 1911 the decedent and Ernest J. Sehweitzer were the owners of the stock of the Wagner-Woodruff Corporation, which was engaged in the business of manufacturing and selling electric lighting fixtures in Los Angeles, Cal.

In 1912 Sehweitzer and the decedent, working in the factory of the…