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DYER v. C. I. R.

No. 17892.

352 F.2d 948 (1965)

J. Raymond DYER and Jean Russell Dyer, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

December 1, 1965.

Attorney(s) appearing for the Case

J. Raymond Dyer, St. Louis, Mo., for petitioners.

Harold K. Wilkenfeld, Atty., Dept. of Justice, Washington, D. C., for respondent. Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Gilbert E. Andrews and Robert A. Bernstein, Attys., Dept. of Justice, Washington, D. C., were on the brief.

Before MATTHES and BLACKMUN, Circuit Judges, and REGISTER, District Judge.

BLACKMUN, Circuit Judge.

J. Raymond Dyer (whom we shall call the taxpayer) and his wife petition for review of a Tax Court decision that there are deficiencies in their cash basis income taxes as jointly returned for the calendar years 1958 and 1959. The deficiencies amount to $417.04 and $362.19, respectively. Judge Black's opinion, not reviewed by the full court, is T.C. Memo. 1964-200.

The challenged amounts are attributable...

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