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ELLIS v. COMMISSIONER

Docket Nos. 34505, 34506.

13 T.C.M. 15 (1954)

Daniel W. Ellis v. Commissioner. Daniel W. Ellis and Anna Swinton W. Ellis v. Commissioner.

United States Tax Court.

Entered January 13, 1954.

Attorney(s) appearing for the Case

J. M. Wells, Esq., Box 626, Greenville, S. C., for the petitioners. A. F. Barone, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The respondent determined deficiencies in income tax of $4,653.94 and $1,352.03 against Daniel W. Ellis for the calendar years 1946 and 1947, and a deficiency in income tax of $290.62 against Daniel and Anna Swinton Ellis for the calendar year 1948. The two cases were consolidated for hearing and opinion. The only question involved is whether the gain realized from the sale of a number of parcels of...

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