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COLLINS v. WOODWORTH

No. 8118.

109 F.2d 628 (1940)

COLLINS v. WOODWORTH, Collector of Internal Revenue.

Circuit Court of Appeals, Sixth Circuit.

February 14, 1940.

Attorney(s) appearing for the Case

George L. Cassidy, of Detroit, Mich. (John C. Evans and George L. Cassidy, both of Detroit, Mich., on the brief), for appellant.

S. Dee Hanson, of Washington, D. C. (James W. Morris, Sewall Key, and Donald J. Marran, all of Washington, D. C., on the brief), for appellee.

Before ALLEN, HAMILTON, and ARANT, Circuit Judges.

HAMILTON, Circuit Judge.

This is an appeal from a judgment of the District Court dismissing the petition of appellant, Jeffrey N. Collins, for recovery of income taxes for the calendar years 1918 and 1919.

The facts are simple. On February 15, 1923, the Commissioner of Internal Revenue notified appellant that, upon audit and review of his income tax returns for calendar years 1918 to 1920 inclusive, he owed additional taxes of $5,072.83. On March 3, 1923,...

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