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LOBUE v. COMMISSIONER

Docket No. 41595.

22 T.C. 440 (1954)

PHILIP J. LOBUE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 28, 1954.

Attorney(s) appearing for the Case

Richard F. Barrett, Esq., for the petitioner.

John E. Mahoney, Esq., for the respondent.

This proceeding involves deficiencies in income tax as follows:

Year                                                             Deficiency

1946 ---------------------------------------------------------   $3,088.63
1947 ---------------------------------------------------------      464.11

The issues to be determined are: (1) Whether the exercise of stock options by petitioner resulted in taxable compensation to him in 1946 and 1947...

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