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STANFORD v. C. I. R.

No. 17279.

297 F.2d 298 (1961)

Julian C. STANFORD and Elizabeth C. Stanford, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

October 23, 1961.

Attorney(s) appearing for the Case

Valentine Brookes, Paul E. Anderson, and Richard A. Wilson, San Francisco, Cal., for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney and William A. Friedlander, Attys. Dept. of Justice, Washington, D. C., for respondent.

Before HAMLEY, JERTBERG and MERRILL, Circuit Judges.

JERTBERG, Circuit Judge.

Before us are petitions for review of the decision of the Tax Court of the United States, reported at 34 T.C. 1150. The petitioners are husband and wife, who filed separate income tax returns on the cash basis for the taxable year 1955. The husband, Julian C. Stanford, will hereafter be called the taxpayer.

The basic and broad question raised by the petitions for review is whether or not the receipt...

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