STEPHENS, Circuit Judge.
The cases of Downs v. Commissioner, No. 11,578, and Hoofnel v. Commissioner, No. 11,593, here from the Tax Court on review, call for decision, mainly, upon the same basic principles. By general agreement they were tried together to the Tax Court, and were argued together here, although the cases are separately briefed. We shall dispose of the two cases in one opinion.
The Commissioner of Internal Revenue found Downs delinquent in his...
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