SOBELOFF, Chief Judge.
For the second time the parties to this case are before us on petition to review a decision of the Tax Court. The sole question raised in the present proceeding is the scope of our mandate in the first.
Litigation between the taxpayer, Joseph N. Romm, and the Commissioner of Internal Revenue began after a deficiency assessment was made for the years 1942 through 1946. The Tax Court sustained the assessed deficiencies and fraud penalties...
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