119 Amos v Commr, 43 TC 50 (1964), aff'd, 360 F2d 358 (4th Cir 1965); Timek v Commr, TC Memo 1976-357, 1976 Tax Ct Memo LEXIS 41. 120 Compare Lowy v Commr, 288 F2d 517, 520 (2d Cir 1961), cert. denied, 368 US 984 (1962) (prior ...
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