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FELDMAN v. COMMISSIONER OF INTERNAL REVENUE

No. 6164.

186 F.2d 87 (1950)

FELDMAN v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fourth Circuit.

Decided December 20, 1950.

Attorney(s) appearing for the Case

Eugene M. Feinblatt, Baltimore, Md. (Simon E. Sobeloff, Baltimore, Md., on brief) for petitioner.

Harry Baum, Special Asst. to the Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., and Ellis N. Slack, Sp. Asst. to the Atty. Gen., on brief), for respondent.

Before PARKER, Chief Judge and SOPER and DOBIE, Circuit Judges.

DOBIE, Circuit Judge.

This is an appeal from a decision of the Tax Court of the United States sustaining a deficiency assessment against the taxpayer on income taxes alleged to be due for the years 1944, 1945 and 1946 in the respective amounts of $16,085.07, $48,733.87 and $27,630.39, the total being $92,449.33 This deficiency was based on the Commissioner's refusal to recognize the Estate of Samuel Feldman, a trust, as a partner in the firm of Brooks Clothes or as...

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