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OSBORNE v. COMMISSIONER

Docket No. 40735.

13 T.C.M. 428 (1954)

T. C. Memo. 1954-27

Robert L. Osborne v. Commissioner.

United States Tax Court.

Filed April 30, 1954.

Attorney(s) appearing for the Case

L. W. Wrixon, Esq., 403 Merchants Exchange Building, San Francisco, Calif., for the petitioner. Edward H. Boyle, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This proceeding involves a deficiency in income tax for the taxable year ending October 31, 1948, in the amount of $3,630.21 determined against the Osborne Engineering Company and assessed against petitioner as transferee of the assets of the company. The issues to be determined are: (1) whether deductions claimed by the corporation on its income tax returns for 1947 and 1948 for...

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