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INGOLD v. COMMISSIONER

Docket Nos. 24221, 24222.

10 T.C.M. 680 (1951)

Ernest Ingold v. Commissioner. Gene Ingold v. Commissioner.

United States Tax Court.

Entered August 10, 1951.

Attorney(s) appearing for the Case

Frederic D. Dassori, Esq., 1775 Broadway, New York, N. Y., for the petitioners. T. M. Mather, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These cases were consolidated for hearing and decision. The respondent determined deficiencies in petitioners' income tax for 1944 as follows:

  Docket No.                          Deficiency

    24221    Ernest Ingold .........   $1,672.15
    24222    Gene Ingold ...........    1,672.72

The question presented for decision is as follows:

Where petitioners, owners of all of the stock in...

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