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COLLINGWOOD v. COMMISSIONER

Docket Nos. 32482, 32483.

20 T.C. 937 (1953)

J. H. COLLINGWOOD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. J. H. COLLINGWOOD AND MARGARET E. COLLINGWOOD, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 4, 1953.

Attorney(s) appearing for the Case

Willard N. Van Slyck, Jr., Esq., and Clayton E. Kline, Esq., for the petitioners.

Everett E. Smith, Esq., for the respondent.

The Commissioner has determined deficiencies in income tax for the years 1947, 1948, and 1949, as follows:

Docket No.                                 Year     Amount

32482 ----------------------------------   1947   $4,529.69
32483 ----------------------------------   1948      800.98
32483 ----------------------------------   1949      795.90

The question to be decided is whether the cost of grading the land of farms into...

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