BLACKMUN, Circuit Judge.
This petition for review concerns the taxpayer's right to dependency credits (under the 1939 Code) and exemption deductions (under the 1954 Code) for two grandchildren for the income tax calendar years 1953 and 1954. The issue was decided adversely to the taxpayer, T.C. Memo. 1962-148, 21 T.C.M.
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