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ROSENTHAL v. COMMISSIONER

Docket No. 28414.

13 T.C.M. 482 (1954)

T. C. Memo. 1954-47

Paul Rosenthal v. Commissioner.

United States Tax Court.

Filed May 21, 1954.

Attorney(s) appearing for the Case

Henry Epstein, Esq., and Edwin D. Hays, Esq., 30 Broad Street, New York, N. Y., for the petitioner. Ellyne E. Strickland, Esq., for the respondent.

Memorandum Supplemental Findings of Fact and Opinion

WITHEY, Judge:

This proceeding is before us under mandate from the United States Court of Appeals for the Second Circuit for further proceedings in accordance with the opinion of that court which appears at 205 Fed. (2d) 505 [53-2 USTC ¶ 10,908]. In its opinion the court reversed our holding at 17 T.C. 1047 [Dec. 18,681] that certain transfers made by petitioner to...

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