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POLETTI v. C. I. R.

No. 17968.

351 F.2d 345 (1965)

Madyo A. POLETTI and Marian Poletti, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

October 19, 1965.

Attorney(s) appearing for the Case

Edward H. Tenney, Jr., of Tenney, Dahman & Mathewson, St. Louis, Mo., for petitioners.

Fred R. Becker, Asst. Atty. Gen., Dept. of Justice, Washington, D. C., John B. Jones, Jr., Acting Asst. Atty. Gen., Dept. of Justice, Washington, D. C., Lee A. Jackson, Harry Baum and J. Edward Shillingburg, Attorneys, Dept. of Justice, Washington, D. C., on the brief, for respondent.

Before MATTHES, RIDGE and GIBSON, Circuit Judges.

MATTHES, Circuit Judge.

For the second time this case is before us on a petition to review the Tax Court's determination of the income tax liability of petitioners for the years 1955, 1956 and 1957. The key issue in the first appeal was whether the Tax Court erred in failing to apply the Cohan rule1 to a portion of the expenditures made by petitioners. We decided that issue in favor of petitioners...

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