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CLEVELAND CHIROPRACTIC COLLEGE v. C. I. R.

No. 17086.

312 F.2d 203 (1963)

CLEVELAND CHIROPRACTIC COLLEGE, a corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

January 17, 1963.

Attorney(s) appearing for the Case

V. E. Phillips, Kansas City, Mo., for petitioner.

V. E. Youngman, Attorney, Department of Justice, Washington, D. C., John B. Jones, Jr., Acting Asst. Atty. Gen., Washington, D. C., Lee A. Jackson, David O. Walter, Alan D. Pekelner, Attorneys, Department of Justice, Washington, D. C., on the brief, for respondent.

Before JOHNSEN, Chief Judge, and MATTHES and RIDGE, Circuit Judges.

RIDGE, Circuit Judge.

On this petition to review a decision of the Tax Court (unreported), the salient questions presented are whether petitioner had net earnings in the years 1948, 1950 and 1951 and whether it was entitled to a tax-exempt status during 1948-52 under Section 101(6) of the Internal Revenue Code of 1939. A subsidiary question is whether petitioner was rightfully subjected to additions under Section 293(a) of the 1939 Code on the amount of the deficiency...

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