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HELVERING v. CAMPBELL

Nos. 5129, 5130.

139 F.2d 865 (1944)

HELVERING, Com'r of Internal Revenue, v. CAMPBELL. SAME v. NELL.

Circuit Court of Appeals, Fourth Circuit.

January 10, 1944.

Attorney(s) appearing for the Case

Carlton Fox, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Helen R. Carloss, Sp. Assts. to Atty. Gen., on the brief), for petitioner and cross-respondent.

Clark J. Milliron, of Los Angeles, Cal., for respondents and cross-petitioners.

Before PARKER, SOPER, and DOBIE, Circuit Judges.

PARKER, Circuit Judge.

These are petitions and cross petitions to review decisions of the United States Tax Court in cases involving the tax liability of Oscar F. Campbell and Edward J. Nell. Both taxpayers during the tax years in question were citizens of the United States, married and residing with their wives in the Philippine Islands. In 1939 Campbell and wife filed income tax returns for the years 1918, 1919 and 1920 with the Collector at Baltimore. During the...

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