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SEABROOK v. COMMISSIONER OF INTERNAL REVENUE

No. 13677.

196 F.2d 322 (1952)

SEABROOK v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

April 18, 1952.

Attorney(s) appearing for the Case

Robert Ash, Washington, D. C., Chas. S. Ausley, Tallahassee, Fla., for petitioner.

Robert M. Weston and Ellis N. Slack, Sp. Assts. to Atty. Gen., Theron Lamar Caudle, Asst. Atty. Gen., Charles Oliphant, Chief Counsel, and John M. Morawski, Sp. Atty., Bureau of Internal Revenue, Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and BORAH and RIVES, Circuit Judges.

BORAH, Circuit Judge.

This is the second review of this case in this court. When it was here before we withheld decision until the Supreme Court had decided the case of Commissioner v. Culbertson, 337 U.S. 733, 69 S.Ct. 1210, 93 L.Ed. 1659, and then we ordered a reversal of the Tax Court's opinion and judgment and remanded the cause to the Tax Court for further proceedings in conformity with the Supreme Court's opinion in the Culbertson...

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