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MILLER v. COMMISSIONER OF INTERNAL REVENUE

Nos. 11551, 11552.

203 F.2d 350 (1953)

MILLER v. COMMISSIONER OF INTERNAL REVENUE (two cases).

United States Court of Appeals Sixth Circuit.

March 19, 1953.

Attorney(s) appearing for the Case

Lee C. McCandless, Butler, Pa. (Lee C. McCandless, Butler, Pa., on the brief), for petitioners.

S. Dee Hanson, Washington, D. C. (Charles S. Lyon, Ellis N. Slack and S. Dee Hanson, Washington, D. C., on the brief), for respondent.

Before ALLEN, McALLISTER and MILLER, Circuit Judges.

McALLISTER, Circuit Judge.

These cases come again before us after remand and subsequent rehearing before the Tax Court. See Miller v. Commissioner, 6 Cir., 183 F.2d 246. A comprehensive statement of the facts may be found in our prior opinion. This appeal is taken from the Tax Court's decision holding that the taxpayers, Sam H. Miller and Florence Miller, in making alleged transfers of portions of their interests in their partnership...

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