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PATTON v. COMMISSIONER OF INTERNAL REVENUE

No. 10534.

168 F.2d 28 (1948)

PATTON et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Sixth Circuit.

April 19, 1948.

Attorney(s) appearing for the Case

L. F. Loux, of Cleveland, Ohio (L. F. Loux, of Cleveland, Ohio, on the brief), for petitioners.

S. Dee Hanson, of Washington, D. C. (Theron L. Caudle, Sewall Key, A. F. Prescott and S. Dee Hanson, all of Washington, D. C., on the brief), for respondent.

Before HICKS, McALLISTER and MILLER, Circuit Judges.

HICKS, Circuit Judge.

Respondent found a deficiency in the income and victory taxes for 1943 of petitioner, James F. Patton, in the sum of $16,561.12, and of petitioner, Vincent Patton, in the sum of $16,361.80. The cases were consolidated for hearing before the Tax Court and here. The Tax Court confirmed the deficiency assessments and we are asked to review its decision.

The cases arose under Sec. 23, Internal Revenue Code, 26 U.S.C.A.Int.Rev.Code, §...

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