Richard A. Allen and Barbara Allen, Appellants, v. Commissioner of Internal Revenue.richard A. Allen, Appellant, v. Commissioner of Internal Revenue, 410 F.2d 398 (3d Cir. 1969)

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US Court of Appeals for the Third Circuit - 410 F.2d 398 (3d Cir. 1969) Argued April 24, 1969
Decided June 4, 1969
Rehearing Denied July 3, 1969

Appeal from Tax Court of the United States; Arnold Raum, Judge.

Robert R. Batt, Ballard, Spahr, Andrews & Ingersoll, Philadelphia, Pa. (Sherwin T. McDowell, Lynn L. Detweiler, Jr., Philadelphia, Pa., Ballard, Spahr, Andrews & Ingersoll, Philadelphia, Pa., on the brief), for appellants.

Edward Lee Rogers, Department of Justice, Tax Division, Washington, D. C. (Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson, Gilbert E. Andrews, Attys., Department of Justice, Washington, D. C., on the brief), for appellee.


Before BIGGS, FREEDMAN and STAHL, Circuit Judges.


A careful examination of the record in this case and consideration of the applicable law demonstrate that the Tax Court committed no error.

Consequently the decisions of the Tax Court will be affirmed.