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TREBOTICH v. C. I. R.

No. 72-1714.

492 F.2d 1018 (1974)

Thomas TREBOTICH and Jeanne Trebotich, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

February 20, 1974.

Attorney(s) appearing for the Case

Norman Leonard (argued), Benjamin O. Andersen of Gladstein, Leonard, Patsey & Andersen, San Francisco, Cal., for appellants.

Wesley J. Filer (argued), Scott P. Crampton, Asst. Atty. Gen., Tax Div., U. S. Dept. of Justice, Washington, D. C., Lee H. Henkel, Jr., Acting Chief Counsel, IRS, Washington, D. C., for appellee.

Before TRASK, GOODWIN, and SNEED, Circuit Judges.

OPINION

SNEED, Circuit Judge:

In November of 1961, the Pacific Maritime Association (PMA), an organization of West Coast shipping industry employers formed for the primary purpose of negotiating and administering maritime union labor contracts, and the International Longshoremen's and Warehousemen's Union (ILWU), a labor organization representing West Coast dock workers, entered into a Memorandum of Agreement on...

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