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OMELIAN v. COMMISSIONER

Docket Nos. 32675, 32676.

12 T.C.M. 306 (1953)

Leo J. Omelian v. Commissioner. Leo J. Omelian and Helen Omelian v. Commissioner.

United States Tax Court.

March 23, 1953.

Attorney(s) appearing for the Case

James A. Quisenberry, Esq., for the petitioners. James A. Anderson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These consolidated proceedings involve deficiencies in income tax and penalty as follows:

  Docket No.    Year            Deficiency     Penalty

    32675       1947 ........    $5,248.72    $1,049.75
    32676       1948 ........     4,674.00     .......

The issues presented are (1) whether the respondent's action is computing the gross profit of the Superior Oil Works, a sole proprietorship, for...

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