FRIENDLY, Circuit Judge.
Petitioner is a well-known author, residing in Connecticut. She kept her records and filed her tax returns on a cash basis. She had a literary agent, named — somewhat inappropriately as things turned out — Rowe Wright. From January 1, 1942 to June 6, 1952, Rowe Wright received royalties aggregating $65,623.58 for petitioner's account from various foreign publishers. In five of the years Wright reported and remitted nothing to...
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