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MANNING v. C. I. R.

No. 79-1418.

614 F.2d 815 (1980)

Elinor W. MANNING, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, First Circuit.

Decided February 11, 1980.

Attorney(s) appearing for the Case

Richard deY. Manning, New York City, with whom Steven R. Hayes, New York City, was on brief, for petitioner, appellant.

James F. Miller, Atty., Tax Division, Dept. of Justice, Washington, D. C., with whom M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, and Helen A. Buckley, Attys., Tax Division, Dept. of Justice, Washington, D. C., were on brief, for respondent, appellee.

Before COFFIN, Chief Judge, CAMPBELL and BOWNES, Circuit Judges.

BOWNES, Circuit Judge.

Petitioner-appellant Elinor W. Manning appeals from the decision of the United States Tax Court finding deficiencies in her federal income tax for the tax years 1972, 1973, and 1974 and assessing delinquency penalties for failure to file tax returns for those years.1 The two issues she raises on appeal and the arguments supporting them are the same as those already treated...

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