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GOWANS v. COMMISSIONER

Docket No. 50427.

16 T.C.M. 1078 (1957)

T.C. Memo. 1957-233

Louis L. Gowans and Helen T. Gowans (Husband and Wife) v. Commissioner.

United States Tax Court.

Filed December 18, 1957.

Attorney(s) appearing for the Case

Frank D. Padgett, Esq., for the petitioners. Donald P. Chehock, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

LEMIRE, Judge:

This proceeding is here upon remand from the United States Circuit Court of Appeals for the Ninth Circuit (246 Fed. (2d) 448) [57-2 USTC ¶ 9830], reversing the decision of this Court entered July 5, 1956 [15 TCM 672, Dec. 21,768(M); T.C. Memo. 1956-133], and remanding the case for further proceedings consistent with its opinion filed June 17, 1957.

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