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EHLERS v. VINAL

No. 18578.

382 F.2d 58 (1967)

William A. EHLERS and William A. Ehlers, Executor of the Estate of Margaret C. Ehlers, Deceased, Appellant, v. Richard P. VINAL, District Director of Internal Revenue for the District of Nebraska, Appellee.

United States Court of Appeals Eighth Circuit.

Rehearing Denied September 8, 1967.

Attorney(s) appearing for the Case

Walter H. Cropper, Omaha, Neb., for appellant, J. Patrick Thornton and William A. Ehlers, Omaha, Neb., with him on brief.

Donald A. Statland, Atty., Dept. of Justice, Washington, D. C., for petitioner, Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and David O. Walter, Attys., Dept. of Justice, and Theodore L. Richling, U. S. Atty., Omaha, Neb., with him on brief.

Before VAN OOSTERHOUT, MATTHES and LAY, Circuit Judges.

LAY, Circuit Judge.

Taxpayer instituted this action against the District Director of Internal Revenue for the District of Nebraska to recover an alleged overpayment of income taxes, penalties and interest for the years 1948 through 1958, in the total amount of $122,344.91 plus interest.1

The taxpayer, appellant in this court, is an attorney. This litigation arises from his purchase of various properties in and about Omaha, Nebraska...

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