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C. I. R. v. MOFFAT

No. 15867.

373 F.2d 844 (1967)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Robert Y. MOFFAT, Sr., and Grace S. Moffat, Respondents.

United States Court of Appeals Third Circuit.

Decided March 6, 1967.

Attorney(s) appearing for the Case

William A. Friedlander, Atty., Dept. of Justice, Tax Div., Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., on the brief), for petitioner.

David B. Buerger, Pittsburgh, Pa. (William Y. Rodewald, Buchanan, Ingersoll, Rodewald, Kyle & Buerger, Pittsburgh, Pa., on the brief), for respondents.

Before GANEY, SMITH and FREEDMAN, Circuit Judges.

OPINION OF THE COURT

GANEY, Circuit Judge.

The Commissioner of Internal Revenue seeks a review of the Tax Court's decision allowing the taxpayer1 an ordinary deduction of $544,000 as a business bad debt for the year 1960. The issues posed are: (1) Was the taxpayer's leasing of coal lands to a corporation a business within the meaning of the Internal Revenue Code of 1954? And if so, ...

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