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HOLLYWOOD BASEBALL ASSOCIATION v. COMMISSIONER

Docket No. 93647.

49 T.C. 338 (1968)

HOLLYWOOD BASEBALL ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 15, 1968.

Attorney(s) appearing for the Case

Arthur E. Gore, for the petitioner.

Melvin L. Sears and Roger Rhodes, for the respondent.

FORRESTER, Judge:

This case is before us on remand from the U.S. Court of Appeals for the Ninth Circuit "for fresh fact findings, addressed to the statute [sec. 337(b) (1) (A), I.R.C. 1954]1 as the Supreme Court has now construed it. See Malat v. Riddell, 383 U.S. 569."

In our original opinion, 42 T.C. 234, filed April 21, 1964, we held, under...

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