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EAGAN v. COMMISSIONER

Docket Nos. 33827, 33931.

12 T.C.M. 876 (1953)

Edward Eagan and Mary Eagan v. Commissioner. Leo T. Eagan and Eleanor D. Eagan v. Commissioner.

United States Tax Court.

Entered July 31, 1953.

Attorney(s) appearing for the Case

Benjamin E. Shove, Esq., 800 Hills Building, Syracuse, N. Y., for the petitioners. Clay C. Holmes, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income taxes for the year 1947 against petitioners as follows:

  Docket No. 33827    $49,716.73
  Docket No. 33931    48,173.52

The proceedings were consolidated for trial. The sole issue is whether petitioners realized taxable income in 1947 by acquiring from City Investing Company for $23,100 Onondaga Holding Corporation and Salina Holding...

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