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UNITED STATES v. RAMOS

Nos. 21824, 21824 A.

393 F.2d 618 (1968)

UNITED STATES of America, Appellant and Cross-Appellee, v. Joe R. RAMOS and Mary Ramos, Appellees and Cross-Appellants.

United States Court of Appeals Ninth Circuit.

Rehearing Denied June 25, 1968.

Attorney(s) appearing for the Case

Stephen H. Paley (argued), Lee A. Jackson, Loring W. Post, Attys., Dept. of Justice, Mitchell Rogovin, Asst. Atty. Gen., Washington, D. C., Cecil Poole, U. S. Atty., Richard L. Carico, Asst. U. S. Atty., San Francisco, Cal., for appellant.

Jasper C. De Dobbeleer (argued), Jerome A. Duffy, San Rafael, Cal., for appellee.

Before CHAMBERS, JERTBERG and ELY, Circuit Judges.

Rehearing Denied in No. 21824 June 25, 1968.

JERTBERG, Circuit Judge:

Before us are two family partnership cases. Both involve federal income tax claims, — one for the year 1956, and the other for the year 1957. The two cases were consolidated for trial in the district court, and are before this court on a consolidated record.

In the first case, the Commissioner of Internal Revenue determined that the entire income from a partnership allegedly...

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