COMMISSIONER OF INTERNAL REVENUE v. RAPHAEL

No. 10138.

133 F.2d 442 (1943)

COMMISSIONER OF INTERNAL REVENUE v. RAPHAEL. RAPHAEL v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Ninth Circuit.

Rehearing Denied March 15, 1943.


Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Asst. Atty. Gen. and Sewall Key, Helen R. Carloss, Newton K. Fox, and Warren F. Wattles, Sp. Assts. to the Atty. Gen., for the Commissioner.

Byron C. Hanna, Harold C. Morton, and Leon B. Brown, all of Los Angeles, Cal., for Marguerite Cahn Raphael.

Before DENMAN, MATHEWS, and STEPHENS, Circuit Judges.


DENMAN, Circuit Judge.

Marguerite Cahn Raphael, a resident of France, hereafter called the taxpayer, petitions for a review of a decision of the United States Board of Tax Appeals, now named the Tax Court of the United States, and the Commissioner of Internal Revenue also petitions for a review of the same decision.

The petitions are considered together. They involve income taxes for the fiscal year ending January 31, 1940, upon moneys received by the taxpayer...

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