Memorandum Findings of Fact and Opinion Sur Mandate
VAN FOSSAN, Judge:
These cases are presently before us on reversal by and remand of the Court of Appeals for the Second Circuit [54-1 USTC ¶ 9280]. The Court of Appeals (Judge Clark dissenting) held that since we had made no explicit finding of fact "of lack of good faith intention" on the part of the several women involved in the alleged joint venture, it must reverse our holding, stating:
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