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LEVY v. COMMISSIONER

Docket Nos. 31256 and 31257.

12 T.C.M. 235 (1953)

Arnold Levy v. Commissioner. Louise B. Levy v. Commissioner.

United States Tax Court.

March 9, 1953.

Attorney(s) appearing for the Case

Edward J. Nelson, Esq., and James I Keller, C. P. A., 1701 du Pont Building, Miami, Fla., for the petitioners. F. L. Van Haaften, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

These consolidated proceedings involve income tax deficiencies for the calendar year 1946 in the amounts of $6,060.07 determined against Arnold Levy and $6,251.36 determined against Louise B. Levy.

In both proceedings the issue presented is whether the respondent, in determining the petitioners' distributive shares of the net income of a partnership, erred in disallowing a claimed deduction...

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