¶1dissenting: I believe that Congress’ omission of the qualifying phrase “directly or indirectly” from the critical portion of section 1239 was studied and would therefore reach the opposite result.
35 T.C. 550
Mitchell v. Commissioner
Decided December 30, 1960
Good law ✅— No negative treatment on recordhow we know
Decision will be entered for the respondent · Decided 1960-12-30
How this case has been cited
Cited by 8 later decisions — most recently February 1980
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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