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BROWN v. COMMISSIONER OF INTERNAL REVENUE

No. 5133.

22 F.2d 797 (1927)

BROWN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

December 2, 1927.

Attorney(s) appearing for the Case

Frank M. Dixon, of Birmingham, Ala., for petitioner.

Mabel Walker Willebrandt, Asst. Atty. Gen., A. W. Gregg, Gen. Counsel, Internal Revenue, of Washington, D. C. (Harvey R. Gamble, Sp. Asst. Atty. Gen., and John W. Fisher, Sp. Atty., Internal Revenue, of Washington, D. C., on the brief), for respondent.

Before WALKER, BRYAN, and FOSTER, Circuit Judges.

FOSTER, Circuit Judge.

This is a petition to review a decision of the United States Board of Tax Appeals. D. H. Brown, the taxpayer, an inhabitant of Alabama, residing and doing business in Birmingham, filed his returns of income taxes for the years 1918, 1919, and 1920. Seeking to bring himself within the provisions of section 214 of the Revenue Act of 1918 (Comp. St. § 6336 1/8g), and similar later statutes, in his returns for 1918 and 1919 he deducted a total...

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