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SMITH v. C. I. R.

No. 7085.

313 F.2d 16 (1962)

V. Zay SMITH, and Ida Smith, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Tenth Circuit.

Rehearing Denied April 3, 1963.

Attorney(s) appearing for the Case

Frank M. Cavanaugh, Denver, Colo., for petitioners.

Melva M. Graney, Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Arthur I. Gould, Attorneys, Department of Justice, were with her on the brief), for respondent.

Before PICKETT, BREITENSTEIN and HILL, Circuit Judges.

HILL, Circuit Judge.

This case is here on the Smiths' Petition To Review a decision of the Tax Court of the United States which was adverse to them.1

The facts necessary for our disposition of the case are not in dispute. In January, 1947, V. Zay Smith (petitioner) and three other individuals formed a partnership known as Geophoto Services (Geophoto) for the purpose of engaging in the business of evaluating geological structures...

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