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DYKEMA v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12012, 12013.

218 F.2d 535 (1954)

Raymond K. DYKEMA and Estate of Albert W. Russell, Deceased, Catherine R. Peck, Central National Bank of Cleveland, and Raymond K. Dykema, Executors, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Sixth Circuit.

December 16, 1954.

Attorney(s) appearing for the Case

Paul R. Trigg, Jr., and Raymond K. Dykema, Detroit, Mich., for petitioners.

H. Brian Holland, Kenneth W. Gemmill, Ellis N. Slack, Robert N. Anderson, S. Dee Hanson, Daniel A. Taylor and John M. Morawski, Washington, D.C., for respondent.

Before ALLEN, McALLISTER and STEWART, Circuit Judges.

PER CURIAM.

This cause came on to be heard upon the record and briefs and oral argument of counsel;

And it appearing that petitioners in the taxable year 1946 paid in proportional shares $5,400 as attorneys' fee, which they deducted in full from gross income upon the ground that these amounts constituted non-business expenses paid for the production or collection of income;

And it appearing that the Tax Court...

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