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BEACHAM v. COMMISSIONER OF INTERNAL REVENUE

No. 17003.

255 F.2d 103 (1958)

L. Lamar BEACHAM and Edith R. Beacham, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied June 2, 1958.

Attorney(s) appearing for the Case

L. Lamar Beacham, Jackson, Miss., Creekmore & Beacham, Jackson, Miss., of counsel, for petitioner.

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Earl Schmeidler, Joseph M. Howard and Meyer Rothwacks, Attys., Nelson P. Rose, Chief Counsel, I. R. S., Rollin H. Transue, Sp. Atty., I. R. S., Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and TUTTLE and BROWN, Circuit Judges.

PER CURIAM.

This is an appeal by taxpayers from an adverse decision of the Tax Court, reported at 28 T.C. 598. It involves additions to taxes for failures to file declarations of estimated tax for the years 1951 and 1952, and for substantial underestimates of estimated tax for the same years.

It presents the single question whether the Tax Court erred in holding that Sec. 294(d) (1) and 294(d) (2) of the 1939 Code, 26 U.S.C...

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