Joseph T. MILLER and Crystal V. Miller, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fifth Circuit.https://leagle.com/images/logo.png
March 27, 1956.
March 27, 1956.
Attorney(s) appearing for the Case
Ralph O. Cullen, John W. Prunty, Miami, Fla., for petitioners.
Harry Marselli, Atty., Dept. of Justice, H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Atty., Dept. of Justice, John Potts Barnes, Chief Counsel, Int. Rev. Service, Rollin H. Transue, Sp. Atty., Lee A. Jackson, Frank E. A. Sander, Attys., Dept. of Justice, Washington, D. C., for respondent.
Before HUTCHESON, Chief Judge, and RIVES and BROWN, Circuit Judges.
United States Court of Appeals Fifth Circuit.
HUTCHESON, Chief Judge.
This proceeding1 for redetermination of a deficiency of $24,772.05 in the 1946 income tax of each of the petitioners presented below two questions for decision: (1) Did the respondent properly compute the deficiencies? (2) Is he estopped from asserting them?
The Tax Court, in an opinion2 fully and correctly setting out the facts, answered the first question in the affirmative...
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