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SEABROOK v. COMMISSIONER

Docket No. 9927.

10 T.C.M. 53 (1951)

L. W. Seabrook v. Commissioner.

United States Tax Court.

Entered January 12, 1951.

Attorney(s) appearing for the Case

Carl F. Bauersfeld, Esq., Robert Ash, Esq., Munsey Bldg., Washington 4, D. C., Charles S. Ausley, Esq., and James D. A. Holley, C. P. A., Tampa Theatre Bldg., Tampa, Fla., for the petitioner. F. L. Van Haaften, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

We entered a decision in the above entitled case on the 15th day of December 1947 on the basis of our Memorandum Findings of Fact and Opinion, entered December 12, 1947 [6 TCM 1273, CCH Dec. 16,172(M)]. The decision was for respondent. That decision was reviewed by the United States Court of Appeals for the Fifth Circuit. That Court handed down its opinion on August 2, 1949, 176 Fed. (2d) 605 [49-2 USTC ¶ 9360], reversing...

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