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FEZANDIE & SPERRLE, INC. v. COMMISSIONER

Docket Nos. 112521, 1118.

5 T.C. 1185 (1945)

FEZANDIE & SPERRLE, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 10, 1945.

Attorney(s) appearing for the Case

Richard W. Wilson, Esq., and Franklin C. Ellis, C. P. A., for the petitioner.

Z. N. Diamond, Esq., J. D. Bierman, Esq., and Sidney B. Gambill, Esq., for the respondent.

These proceedings involve the correctness of the determinations of the respondent which disallowed petitioner's applications for relief for the calendar years 1940 and 1941, filed under section 722 (b) (4)

[5 T.C. 1186]
of the Internal Revenue Code. The two proceedings, raising substantially the same questions for each year, were consolidated at the hearing.

In Docket No. 112521 petitioner seeks relief for the calendar year 1940 in the...

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