HICKS, Circuit Judge.
Petition by Benjamin F. Miller to review a decision of the Tax Court affirming the action of the Commissioner of Internal Revenue in assessing on redetermination a deficiency in income taxes of $652.02, $5,184.57, $4,638.61 and $9487.44 for the years 1937, 1938, 1939 and 1940, respectively.
The Commissioner contended, and the Tax Court held, that petitioner was taxable under Section 22(a)
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