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C. BLAKE McDOWELL, INC. v. COMMISSIONER

Docket No. 3852-76.

71 T.C. 71 (1978)

C. BLAKE McDOWELL, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 24, 1978.

Attorney(s) appearing for the Case

C. Blake McDowell, Jr., Gilbert V. Kelling, Jr., and Richard J. Kovach, for the petitioner.

William P. McKeithan, for the respondent.

OPINION

TANNENWALD, Judge:

This case is before the Court on remand from the Sixth Circuit Court of Appeals for reconsideration in light of the Supreme Court's recent decision in Fulman v. United States, 434 U.S. 528 (1978). In particular, petitioner seeks a hearing at which to present evidence as to its reliance on the decision of that circuit in H. Wetter Manufacturing Co. v. United States,

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