Wodehouse v. Commissioner

SUPPLEMENTAL OPINION SUR MANDATE.-

Van Fossan, Judge:

In our original opinion (8 T. C. 637) Docket Nos. 3401 and 6487 were involved and tax^s for the years 1923, 1924, 1937, 1938, 1940 and 1941, and penalties for certain years, were in issue.

Subsequently appeals were prosecuted as to certain of the years in the Circuit Courts of Appeals for the Second, Fourth and Ninth Circuits, resulting in divergent holdings as to one issue. Thereafter, the Supreme Court granted certiorari as to the case in the Fourth Circuit resulting in a reversal of the Court of Appeals for the Fourth Circuit and the…