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MacRAE v. C. I. R.

No. 17128.

294 F.2d 56 (1961)

Albert Gordon MacRAE and Sheila MacRae, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

August 28, 1961.

Attorney(s) appearing for the Case

Bernard Speisman, New York City, and Jerome B. Rosenthal, Beverly Hills, Cal., for petitioner.

John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, Harry Baum and Norman H. Wolfe and Carolyn R. Just, Attorneys, Dept. of Justice, Washington, D. C., for respondent.

Before HAMLEY, JERTBERG and MERRILL, Circuit Judges.

JERTBERG, Circuit Judge.

Before us is a petition for review of a decision of the Tax Court of the United States, reported at 34 T.C. 20. The petitioners are husband and wife who filed joint returns on the cash basis for the taxable years 1952 and 1953. The husband, Albert Gordon MacRae, will hereinafter be called the taxpayer.

The Tax Court sustained the disallowance by the Commissioner of Internal Revenue of amounts paid by...

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