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CONROY v. COMMISSIONER OF INTERNAL REVENUE

No. 9528.

341 F.2d 290 (1965)

William E. CONROY, Jay C. Dobbs, James W. Jenkins and Charles J. Tauter, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided January 12, 1965.

Attorney(s) appearing for the Case

W. Carroll Parks, Baltimore, Md., for petitioners.

Herbert Grossman, Atty., Dept. of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and I. Henry Kutz, Attys., Dept. of Justice, on brief), for respondent.

Before HAYNSWORTH, Chief Judge, and BOREMAN and J. SPENCER BELL, Circuit Judges.

PER CURIAM.

We concur in the judgment of the Tax Court that the proceeds received by these taxpayers from the Special Fund of the Baltimore City Police Department were includable in their gross income for federal income taxation purposes. In order for the taxpayers to prevail in their contention that these proceeds were excludable from gross income under the provisions of § 104(a) (3) read in conjunction with § 105(e), it would be necessary for us to reach...

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