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GALT v. COMMISSIONER

Docket Nos. 27844, 29528.

19 T.C. 892 (1953)

ARTHUR T. GALT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 27, 1953.

Attorney(s) appearing for the Case

Walter W. Ross, Esq., Gerhard E. Seidel, Esq., and Elroy C. Sandquist, Jr., Esq., for the petitioner.

Thomas A. Steele, Jr., Esq., for the respondent.

Respondent determined deficiencies in petitioner's taxes for 1946 as follows:

Docket No. 27844 -------------   Gift tax ------------   $68,079.00
Docket No. 29528 -------------   Income tax ----------    69,622.52

Concessions have been made by petitioner and respondent with respect to their claims relating to both the income and gift tax deficiencies.

The following issues remain in controversy: (1) Is petitioner subject to income tax on certain...

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