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SASS v. COMMISSIONER

Docket No. 44652.

13 T.C.M. 1091 (1954)

T. C. Memo. 1954-212

Elliot D. Sass v. Commissioner.

United States Tax Court.

Filed November 30, 1954.

Attorney(s) appearing for the Case

Victor Feingold, Esq., 509 Madison Avenue, New York, N. Y., for the petitioner. Arthur L. Nims, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined deficiencies and additions to the tax in petitioner's income tax, as follows:

                       25 per cent    50 per cent
  Year       Amount      Penalty        Penalty

  1946...  $32,013.61    $8,003.40     $16,006.80
  1947...      207.22     ........      .........

Respondent abandoned his determination of a 50 per cent fraud penalty in the amount of $16,006.80 and...

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