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W. D. GALE, INC. v. C. I. R.

Nos. 14551, 14552.

297 F.2d 270 (1961)

W. D. GALE, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Joseph A. SCHOENITH and Mildred A. Schoenith, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

December 29, 1961.

Attorney(s) appearing for the Case

Walter J. Murray, Detroit, Mich., and Pell Hollingshead, Detroit, Mich., for petitioners.

William A. Friedlander, Department of Justice, Washington, D. C., John B. Jones, Jr., Acting Asst. Atty. Gen., Lee A. Jackson, A. F. Prescott, Attorneys, Department of Justice, Washington, D. C., on brief, for respondent.

Before MILLER, Chief Judge, CECIL, Circuit Judge, and DARR, Senior District Judge.

ORDER.

These causes are before the Court on petitions of taxpayers W. D. Gale, Inc., and Joseph A. Schoenith and Mildred A. Schoenith, individually, for review of decisions and orders of the Tax Court of the United States. The Tax Court found that there were deficiencies in income tax of the taxpayers for the taxable years ended December 31, 1953, December 31, 1954 and December 31, 1955.

The deficiencies of the corporate taxpayer arose by reason of the disallowance...

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