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GEORDAY ENTERPRISES v. COMMISSIONER OF INTERNAL REV.

Nos. 4818, 4819.

126 F.2d 384 (1942)

GEORDAY ENTERPRISES, Limited, v. COMMISSIONER OF INTERNAL REVENUE. HELVERING, Commissioner of Internal Revenue, v. GEORDAY ENTERPRISES, Limited.

Circuit Court of Appeals, Fourth Circuit.

March 9, 1942.

Attorney(s) appearing for the Case

Richard H. Wilmer, of Washington, D. C. (Joseph C. White and Thomas F. Boyle, both of New York City, on the brief), for Georday Enterprises.

Hubert L. Will, Sp. Asst. to the Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and J. Louis Monarch and Lee A. Jackson, Sp. Assts. to the Atty. Gen., on the brief), for Commissioner of Internal Revenue.

Before PARKER, SOPER and DOBIE, Circuit Judges.

DOBIE, Circuit Judge.

This is a petition for the review of a decision of the United States Board of Tax Appeals determining a deficiency in the income tax liability of Georday Enterprises, Limited (hereinafter called Georday), for the calendar year 1932 in the sum of $50,875, and a 25% penalty in the sum of $12,718.75 for the same year. The memorandum opinion of the Board, entered on December 3, 1940, is unreported.

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