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LICAVOLI v. C. I. R.

No. 15073.

318 F.2d 281 (1963)

Peter and Grace LICAVOLI, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

June 6, 1963.

Attorney(s) appearing for the Case

John F. Noonan, Detroit, Mich. (Stanley M. Rosenblum, St. Louis, Mo., of counsel), for petitioners.

Thomas A. Skornia, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Meyer Rothwacks, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before MILLER and O'SULLIVAN, Circuit Judges, and TAYLOR, District Judge.

PER CURIAM.

The taxpayers, Peter and Grace Licavoli, sought redetermination in the Tax Court of deficiency income tax assessments for the years 1947 through 1951. Action No. 58055 involved income taxes of Grace Licavoli for 1947. Action No. 58056 involved income taxes of Peter Licavoli for the same year. Action No. 58057 involved the joint income tax liability of both taxpayers for the years 1948 through 1951. The Commissioner in his answers relied upon the net worth...

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