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HARDY v. COMMISSIONER OF INTERNAL REVENUE

No. 9887.

125 F.2d 863 (1942)

HARDY v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

February 18, 1942.

Attorney(s) appearing for the Case

Mackay, McGregor & Reynolds, of Los Angeles, Cal. (A. Calder Mackay, Howard W. Reynolds, Arthur McGregor, and Benjamin W. Shipman, all of Los Angeles, Cal., of counsel), for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and J. Jouis Monarch, Gerald L. Wallace, and Harry Marselli, Sp. Assts. to the Atty. Gen., for respondent.

Before MATHEWS, HANEY, and STEPHENS, Circuit Judges.

STEPHENS, Circuit Judge.

The Commissioner determined deficiencies in petitioner taxpayer's income taxes for the years 1934, 1935, 1936 and 1937, and the taxpayer instituted three separate proceedings before the Board of Tax Appeals for redetermination of the deficiencies. The proceedings were consolidated for hearing, and the Board sustained the Commissioner's determination. The present petition for review followed.

The proposed deficiencies arise by reason...

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