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UNITED STATES v. IVEY

No. 18568.

303 F.2d 109 (1962)

UNITED STATES of America, Appellant, v. Harold W. IVEY and Mrs. Virginia Ivey, Appellees. Harold W. IVEY and Mrs. Virginia Ivey, Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals Fifth Circuit.

May 16, 1962.

Attorney(s) appearing for the Case

Howard A. Heffron, Acting Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., Charles D. Read, Jr., U. S. Atty., Slaton Clemmons, Asst. U. S. Atty., Atlanta, Ga., David O. Walter, Atty., Dept. of Justice, Washington, D. C., for appellant.

Allen Post, J. Wm. Gibson, Alex McLennan, Atlanta, Ga., for appellees.

Before RIVES, CAMERON, and WISDOM, Circuit Judges.

PER CURIAM.

Both parties have petitioned for a rehearing in this case. Neither has raised any argument or cited any authorities not already considered by the Court. Accordingly, we deny the petitions. We take advantage of this opportunity, however, to clarify one aspect of our holding. 294 F.2d 799.

On the original hearing, we decided that the collapsible corporation provisions, Section 117(m) of the 1939 Internal Revenue...

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