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COMMISSIONER OF INTERNAL REVENUE v. HAMMEL

No. 8043.

108 F.2d 753 (1940)

COMMISSIONER OF INTERNAL REVENUE v. HAMMEL et ux.

Circuit Court of Appeals, Sixth Circuit.

January 10, 1940.

Attorney(s) appearing for the Case

Arthur A. Armstrong, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key and Arthur A. Armstrong, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

John J. Sloan, of Detroit, Mich. (John J. Sloan, of Detroit, Mich., and Godfrey Hammel, on the brief), for respondents.

Before HICKS, HAMILTON, and ARANT, Circuit Judges.

HAMILTON, Circuit Judge.

This is a petition by the Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals disallowing a deficiency in income taxes of $426 for the calendar year 1934, found by him to be due from the respondents, but disallowed by the Board.

The statutes involved are Sections 23(e) (2), 26 U.S.C.A. § 23(e) (2), Section 111 (a), 26 U.S.C.A. § 111(a), Section 117(a) (b) (d), 26 U.S.C.A. § 101(a, b, d)...

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