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SAM SAMKOFF v. COMMISSIONER

Docket No. 54266.

16 T.C.M. 529 (1957)

T.C. Memo. 1957-123

Sam Samkoff v. Commissioner.

United States Tax Court.

Filed June 28, 1957.

Attorney(s) appearing for the Case

James A. Ronayne, Esq., 120 Broadway, New York, N. Y., for the petitioner. John J. Walsh, Esq., and John M. Doukas, Esq., for the respondent.

Supplemental Memorandum Findings of Fact and Opinion

Memorandum Findings of Fact and Opinion was filed in this case on November 14, 1956, under which decision was to be entered under Rule 50 [15 TCM 1283, Dec. 22,018(M); T.C. Memo. 1956-251]. Decision has not been entered. After the Findings of Fact and Opinion was filed, petitioner's counsel for the first time, and belatedly, advanced a new argument and cited new cases relating...

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