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SCHAEFFER v. COMMISSIONER OF INTERNAL REV.

No. 13421.

258 F.2d 861 (1958)

J. H. SCHAEFFER, Jr., and Opal R. Schaeffer, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

August 20, 1958.

Attorney(s) appearing for the Case

Leo L. Cole, Jr., and James F. Schaeffer, Memphis, Tenn., for petitioners.

Joseph F. Goetten, Washington, D. C., Charles K. Rice, Lee A. Jackson, Robert N. Anderson, Carolyn R. Just, Department of Justice, Washington, D. C., on brief, for respondent.

Before SIMONS, Chief Judge, MILLER, Circuit Judge, and CECIL, District Judge.

SHACKELFORD MILLER, Jr., Circuit Judge.

The petitioners filed this action in the United States Tax Court seeking a redetermination of deficiency income tax assessments for the years 1952 and 1953, resulting from the failure on the part of the petitioners to include in gross income certain credits in their favor on the books of a finance company, which the Commissioner ruled constituted accrued taxable income. The Tax Court...

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