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ROSENTHAL v. COMMISSIONER OF INTERNAL REVENUE

No. 127, Docket 22463.

205 F.2d 505 (1953)

ROSENTHAL v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided June 24, 1953.

Attorney(s) appearing for the Case

Henry Epstein, New York City (Hays, Wolf, Schwabacher, Sklar & Epstein, Edwin D. Hays, and Daniel P. Hays, all of New York City, on the brief), for petitioner.

Harry Marselli, Sp. Asst. to Atty. Gen. (H. Brian Holland, Asst. Atty. Gen., and Ellis N. Slack, Sp. Asst. to Atty. Gen., Washington, D.C., on the brief), for respondent.

Before AUGUSTUS N. HAND, CHASE, and CLARK, Circuit Judges.

CLARK, Circuit judge.

The taxpayer, Paul Rosenthal, petitions for review of a decision of Judge Disney in the Tax Court, reviewed by the entire court, 17 T.C. 1047, in so far as it determines a deficiency of $16,983.17 in his gift tax for 1946 and rejects his claim of overpayment of that tax in the amount of $160,212. In the same decision the court found a deficiency of $23,194.37 in Rosenthal's gift tax for 1944, but neither party...

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