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ENGLE v. COMMISSIONER

Docket Nos. 36585, 36586.

13 T.C.M. 520 (1954)

T. C. Memo. 1954-61

George S. Engle v. Commissioner. George S. Engle and Dorothy J. Engle, Husband and Wife, v. Commissioner.

United States Tax Court.

Filed June 11, 1954.

Attorney(s) appearing for the Case

Carl F. Bauersfeld, Esq., and Robert Ash, Esq., 550 Munsey Building, Washington, D. C., for the petitioners. Neuman A. Townsend, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

These consolidated proceedings involve deficiencies in income tax as follows:

      Petitioner                Year      Amount

  George S. Engle ..........    1946    $18,630.64
  George S. Engle and
   Dorothy J. Engle ........    1947    106,720.23
                                1948    193,852.48

The sole contested issue is whether the gain on the sale of interests in oil leases and royalties...

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