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CASSATT v. COMMISSIONER OF INTERNAL REVENUE

No. 8191.

137 F.2d 745 (1943)

CASSATT v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided August 23, 1943.

Attorney(s) appearing for the Case

Thomas Reath, of Philadelphia, Pa. (Calvin H. Rankin and Frederick E. S. Morrison, both of Philadelphia, Pa., on the brief), for petitioner.

Willard H. Pedrick, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before BIGGS, MARIS, and GOODRICH, Circuit Judges.

MARIS, Circuit Judge.

This is a petition by Alexander J. Cassatt to review a decision of the Board of Tax Appeals sustaining a deficiency in income tax for the year 1936 determined against him by the Commissioner. The relevant facts as found by the Board may be summarized as follows:

The taxpayer was a membor of Cassatt and Company, a limited partnership, which for many years prior to 1935 engaged in the stock brokerage business in New York and Philadelphia...

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