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FAUL v. C. I. R.

No. 15987.

263 F.2d 645 (1959)

Elmer J. FAUL and Sybell E. Faul, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

February 17, 1959.

Attorney(s) appearing for the Case

Heisler & Stewart, Francis Heisler, Charles A. Stewart, Carmel, Cal., for petitioners.

Charles K. Rice, Asst. Atty. Gen., Loring W. Post, Grant W. Wiprud, John J. Pajak, Lee A. Jackson, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before FEE, HAMLIN and JERTBERG, Circuit Judges.

JERTBERG, Circuit Judge.

Before us in this case is a petition to review decision of the Tax Court of the United States. The sole question on this review is whether the finding of the Tax Court that petitioner Elmer J. Faul did not perform services as an informer1 covering a period of 36 calendar months or more (from the beginning to the completion of such services) is clear error, and hence that petitioner is not entitled to income allocation...

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