DENMAN, Circuit Judge.
Marguerite Cahn Raphael, a resident of France, hereafter called the taxpayer, petitions for a review of a decision of the United States Board of Tax Appeals, now named the Tax Court of the United States, and the Commissioner of Internal Revenue also petitions for a review of the same decision.
The petitions are considered together. They involve income taxes for the fiscal year ending January 31, 1940, upon moneys received by the taxpayer...
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