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MANDEL v. COMMISSIONER OF INTERNAL REVENUE

No. 11448.

229 F.2d 382 (1956)

Leon MANDEL and Carolina Panerai Mandel, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

January 13, 1956.

Attorney(s) appearing for the Case

Charles W. Davis, Chicago, Ill., Samuel H. Horne, Washington, D. C., Harry B. Sutter, C. Ives Waldo, Jr., Chicago, Ill. (Hopkins, Sutter, Halls, Owen & Mulroy, Chicago, Ill., of counsel), for petitioners.

H. Brian Holland, Asst. Atty. Gen., George F. Lynch, Atty., Tax Division, U. S. Dept. of Justice, Washington, D. C., Ellis N. Slack, Hilbert P. Zarky, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before DUFFY, Chief Judge, and MAJOR and SCHNACKENBERG, Circuit Judges.

MAJOR, Circuit Judge.

This is a petition to review a decision of the Tax Court, entered January 12, 1955, sustaining respondent's determination of deficiencies in petitioners' income tax returns for the years 1948 and 1949.

We think the contested issues are properly stated in respondent's brief. They are as follows:

"1. Whether the Tax Court erred in holding that payments made in 1948 and 1949 by taxpayer...

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