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WATTLEY v. C. I. R.

No. 49, Docket 27004.

298 F.2d 791 (1962)

Ralph B. WATTLEY and Josephine R. Wattley, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided January 23, 1962.

Attorney(s) appearing for the Case

Ralph B. Wattley, Kew Gardens, N. Y., pro se.

Arthur I. Gould, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson, Washington, D. C., on the brief), for respondent.

Before LUMBARD, Chief Judge, and CLARK and FRIENDLY, Circuit Judges.

PER CURIAM.

The facts relevant to this appeal are stated in our opinion on a prior appeal of this case, reported at 275 F.2d 461, cert. denied, 364 U.S. 864, 81 S.Ct. 107, 5 L.Ed. 2d 86. At that time we remanded the case to the Tax Court for further proceedings not inconsistent with our opinion and, contrary to the taxpayer's1 contentions, the Tax Court's subsequent opinion, T.C. Memo. 1961-24, filed January...

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