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ESTATE OF JOSLYN v. COMMISSIONER

Docket No. 5591-67.

63 T.C. 478 (1975)

ESTATE OF MARCELLUS L. JOSLYN, ROBERT D. MACDONALD, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 28, 1975.

Attorney(s) appearing for the Case

Malcolm George Smith, for the petitioner.

Allan D. Teplinsky and Norman H. McNeil, for the respondent.

SUPPLEMENTAL FINDINGS OF FACT AND OPINION

SIMPSON, Judge:

This case is now before the Court on remand from the United States Court of Appeals for the Ninth Circuit. The case was originally heard by this Court and decided in favor of the Commissioner (57 T.C. 722 (1972)). Upon a petition for review, the Court of Appeals for the Ninth Circuit reversed our decision and remanded the case for further consideration in accordance...

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