Daniel A. Robida v. Commissioner of Internal Revenue

Here we have a petition to review an unreported decision of the Tax Court. The respondent resists the contentions made in the petition, but, at the same time, he moves that we, “in the interest of complete fairness,” remand the case to the Tax Court for further, but limited, proceedings.

Involved are claimed income tax deficiencies for the years 1956 through 1961. There is no dispute over the fact that petitioner derived the income upon which the deficiencies were assessed through his ability to “manipulate” slot machines located in military service clubs, principally in Germany. The…