Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding has been returned to this Court under a mandate from the United States Circuit Court of Appeals for the Fifth Circuit, reading, in part, as follows:
It is now here ordered, adjudged and decreed by this Court, that the judgment of the said Tax Court of the United States in this cause be, and it is hereby, reversed.
In its opinion...
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