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SCHOENBERG v. C. I. R.

No. 16893.

302 F.2d 416 (1962)

Albert SCHOENBERG, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

April 24, 1962.

Attorney(s) appearing for the Case

V. E. Phillips, Kansas City, Mo., made argument for petitioner and filed brief.

Kenneth E. Levin, Atty., Tax Division, Dept. of Justice, Washington, D. C., made argument for the respondent and Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and David O. Walter, Attys., Tax Division, Dept. of Justice, Washington, D. C., filed brief for respondent.

Before VAN OOSTERHOUT and BLACKMUN, Circuit Judges, and HENLEY, District Judge.

VAN OOSTERHOUT, Circuit Judge.

Taxpayer Albert Schoenberg has filed timely petition for review of the decision of the Tax Court filed August 21, 1961, (T.C. Memo. 1961-235, not officially reported) determining deficiencies in tax in the amount of $44,018.48 for the year 1952 and $6646.26 for the year 1954, plus additions for each year under § 294(d) (2) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 294(d) (2).1 Jurisdiction...

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