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SHARAF v. COMMISSIONER OF INTERNAL REVENUE

No. 4958.

224 F.2d 570 (1955)

Simeon SHARAF, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals First Circuit.

July 15, 1955.

Attorney(s) appearing for the Case

Stanley M. Brown, Manchester, N. H., with whom McLane, Carleton, Graf, Greene & Brown, Manchester, N. H., was on brief, for petitioner.

David O. Walter, Sp. Asst. to Atty. Gen., with whom H. Brian Holland, Asst. Atty. Gen., and Ellis N. Slack, Sp. Asst. to Atty. Gen., were on brief, for respondent.

Before MAGRUDER, Chief Judge, and WOODBURY and HARTIGAN, Circuit Judges.

HARTIGAN, Circuit Judge.

This is an appeal from a decision of the Tax Court of the United States filed December 22, 1954, which determined a deficiency in the individual income tax of Simeon Sharaf for the taxable year 1945 in the amount of $5,196.76 and imposed as an addition thereto a negligence penalty in the amount of $259.84.

This deficiency arises out of income found to have been received by the petitioner in 1945 as a consequence of the liquidation...

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