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COMMISSIONER OF INTERNAL REVENUE v. INGRAM

No. 6114.

87 F.2d 915 (1937)

COMMISSIONER OF INTERNAL REVENUE v. INGRAM.

Circuit Court of Appeals, Third Circuit.

January 29, 1937.

Attorney(s) appearing for the Case

Robert H. Jackson, Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to the Atty. Gen., for petitioner.

William A. Seifert, William Wallace Booth, and John A. McCann, all of Pittsburgh, Pa., and Floyd F. Toomey, of Washington, D. C., for respondent.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

PER CURIAM.

In this income tax case the Commissioner appeals from a decision of the Tax Board. The question involved in the case is thus summarized in its opinion:

"The respondent set aside a closing agreement with the petitioner and determined a deficiency of $11,046.70 for 1927, together with a 5 per cent negligence penalty of $552.34. The petitioner relies upon the closing agreement for a decision that there is...

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