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GARNER v. COMMISSIONER

Docket No. 25774.

10 T.C.M. 1243 (1951)

Franklin S. Garner and Emily Garner v. Commissioner.

United States Tax Court.

Entered December 29, 1951.

Attorney(s) appearing for the Case

Arthur Weissbarth, Esq., for the petitioners. Robert Margolis, Esq., and Francis J. Butler, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $2,714.21 in petitioners' income tax for the year 1945, consequent on his disallowance of a loss on the sale of certain property in France.

Findings of Fact

Petitioners are husband and wife residing in the State of New York, who filed their return for the year 1945 with the collector of internal revenue for the first district of New York.

Franklin S. Garner...

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