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WODEHOUSE v. COMMISSIONER

Docket No. 6487.

15 T.C. 799 (1950)

PELHAM G. WODEHOUSE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 6, 1950.

Attorney(s) appearing for the Case

Watson Washburn, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

SUPPLEMENTAL OPINION SUR MANDATE.

VAN FOSSAN, Judge:

In our original opinion (8 T.C. 637) Docket Nos. 3401 and 6487 were involved and taxes for the years 1923, 1924, 1937, 1938, 1940 and 1941, and penalties for certain years, were in issue.

Subsequently appeals were prosecuted as to certain of the years in the Circuit Courts of Appeals for the Second, Fourth and Ninth Circuits, resulting in divergent holdings...

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