Court of Appeals for the Fourth Circuit June 5, 1956, 7110, 7111 (M/v Nonsuco, Inc. v. Commissioner of Internal Revenue, S/s San Vincente, Inc. v. Commissioner of Internal Revenue)

PARKER, Chief Judge.

These are petitions to review a decision of the Tax Court holding that earnings of Philippine flag vessels prior to July 4, 1946 were not entitled to exemption from United States income taxation on the same basis as the earnings of other foreign flag vessels under section 231 (d) (1) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 231(d) (1).