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DOYLE v. COMMISSIONER OF INTERNAL REVENUE

No. 5324.

147 F.2d 769 (1945)

DOYLE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

Rehearing Denied April 9, 1945.

Attorney(s) appearing for the Case

J. Gilmer Korner, Jr., of Washington, D. C. for petitioner.

Harry Baum, 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 respondent.

Before PARKER, SOPER, and DOBIE, Circuit Judges.

DOBIE, Circuit Judge.

This is a petition of Richard S. Doyle to review a decision of the Tax Court of the United States, adverse to Doyle, determining Doyle's income tax for the calendar year 1938. The opinion of the Tax Court is reported in 3 T.C. 1092. We first attempt a brief summary of the rather complicated facts in this case and then discuss the single question of law raised by these facts.

On December 11, 1919, Briggs...

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