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BROWN v. COMMISSIONER OF INTERNAL REVENUE

No. 14640.

215 F.2d 697 (1954)

E. W. BROWN, Jr. and Gladys Slade Brown, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

September 22, 1954.

Attorney(s) appearing for the Case

L. J. Benckenstein and Peter B. Wells, Beaumont, Tex., for petitioners.

S. Dee Hanson, Ellis N. Slack, Lee A. Jackson and Meyer Rothwacks, Sp. Assts. to Atty. Gen., Dept. of Justice, Kenneth W. Gemmill, Acting Chief Counsel, and William D. Crampton, Sp. Atty. Bureau of Int. Rev., and H. Brian Holland, Asst. Atty. Gen., Dept. of Justice, Washington, D. C., for respondent.

Before STRUM and RIVES, Circuit Judges, and DAWKINS, District Judge.

DAWKINS, District Judge.

This is a petition to review the decisions of the Tax Court in four consolidated cases involving deficiencies assessed against petitioners for the years 1945 and 1946. Petitioners are husband and wife who filed separate returns for those years under the Texas community property laws.

Dr. E. W. Brown and his wife, Carrie L. Brown, accumulated considerable community property consisting of commercial and residential properties in Texas...

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