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Lambert v. Commissioner of Internal Revenue

decided: October 30, 1964.

RALPH D. LAMBERT AND MARGOT LAMBERT, ERNEST J. HENLEY AND BARBARA M. HENLEY, MARTHA HENLEY, PETITIONERS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.



Before FRIENDLY, KAUFMAN and ANDERSON, C rcuit Judges.

Per Curiam:

We affirm the judgment of the Tax Court on the opinion of Judge Fay. Although the Commissioner might well have taken a more lenient view on the facts here presented, it is plain that the petitioners did not comply with requirements on which the Commissioner was entitled to insist.

19641030

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