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SABATINI v. COMMISSIONER OF INTERNAL REVENUE

No. 288.

98 F.2d 753 (1938)

SABATINI v. COMMISSIONER OF INTERNAL REVENUE. COMMISSIONER OF INTERNAL REVENUE v. SABATINI.

Circuit Court of Appeals, Second Circuit.

August 4, 1938.

Attorney(s) appearing for the Case

James W. Morris, Asst. Atty. Gen., and Sewall Key, A. F. Prescott, and Alexander Tucker, Sp. Assts. to Atty. Gen., for the Commissioner.

Edgar J. Goodrich, of Washington, D. C., William De Forest Manice, of New York City, and Eugene Meacham, of Washington, D. C. (Guggenheimer & Untermyer, of New York City, of counsel), for Rafael Sabatini.

Before L. HAND, AUGUSTUS N. HAND, and CHASE, Circuit Judges.

CHASE, Circuit Judge.

The taxpayer is an alien; a subject of Great Britain residing in London, England. He is an author who during the years in question was represented in this country by a firm of authors' representatives and part of the time by a New York bank but all in respect to matters other than the tax liabilities here involved. He, neither before nor during the years for which deficiencies in his taxes have been redetermined, was personally in this country...

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