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DEZENDORF v. C. I. R.

No. 19698.

312 F.2d 95 (1963)

Edwin M. DEZENDORF and Florence L. Dezendorf, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Edwin M. DEZENDORF and Florence L. Dezendorf, Respondents.

United States Court of Appeals Fifth Circuit.

January 9, 1963.

Attorney(s) appearing for the Case

David L. Tisinger, Austin, Tex., for petitioners.

William A. Geoghegan, Atty., Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Crane C. Hauser, Chief Counsel, I.R.S., Claude R. Marshall, Atty., I.R.S., Joseph Kovner, Carolyn R. Just, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before HUTCHESON, CAMERON and JONES, Circuit Judges.

JONES, Circuit Judge.

The petitioners, Edwin M. Dezendorf and Florence L. Dezendorf, his wife, seek to set aside a decision of the Tax Court which determined that they were liable for income tax deficiencies for the years 1952 and 1953 found by the respondent, the Commissioner of Internal Revenue. Edwin M. Dezendorf will be referred to as the taxpayer as Mrs. Dezendorf was not a participant in any of the transactions out of...

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