38's didn't have inner fenders as such. I'm not sure of the technical name but they had a side panel on the front. I've got a few pictures of my 38 when I had the engine out being rebuilt that might offer some help. If I can find them I'll post them below.

Those are the panels I'm talking about.  I'm having trouble seeing just how they fit.  Does the flange on the bottom of the panel sit on the frame.  In your pic it doesn't look like it does, but perhaps it's not in the original position in that picture.  Also, I assume it attaches on the top to the fender.  Is that correct?

I no longer own the car so I can't go look. Operating from memory, the panel attaches to the body & core support at the front & rear as well as the fender along the top and floats barely above the frame along the bottom. The computer with my pictures is off for the day. I'll see what other pictures I have that may help tomorrow. The photos above pretty clearly show the mounting forward, aft and along the top. If there are no factory holes along the bottom it won't be bolted to the frame directly.

I very much appreciate your help with this, Tiny.  There are small holes along the bottom of the panels, but I think they are for rivets to attach anti-squeek padding.  That's assuming the panel rides along the top of the frame.  

I found some that I took at the shop doing the restoration body work. It looks like the fasteners along the top of the panel/fender may be rivets rather than bolts/screws. The shop didn't separate them from the fenders which they would have done had there been screw fasteners. Unfortunately I don't find any that show specifically that part of the panel. I would wager some money that you're correct about the anti-squeek. I'll post some of what I have in my archive below.

A friend and I may have solved the question today.  It appears that the holes across the top of the inner panel correspond to holes along the top of the fender.  I agree that they were probably for rivets, given the diameter of the holes.  When those holes are lined up with the fender, it leaves about 1/2 inch or so sticking above the top of the fender line, which will be hidden by the hood.  I also agree with your earlier recollection that the inner panel sort of floats above the frame, being attached at the top to the fender.  I'm also thinking the rear end of the inner panel also floats, without being attached to the firewall.  Your pics are an excellent guide and pretty much confirm my thoughts.  Those pics and your comments have been a huge help, Tiny.  I can't thank you enough.

@koznisky-2 You are very welcome. You might consider joining the club if you haven't already and getting access to the many benefits of membership, only one of which is free access to our Technical Advisors. Hope to see you on the road!