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PALERMO v. COMMISSIONER

Docket No. 38750.

13 T.C.M. 565 (1954)

T. C. Memo. 1954-74

James Palermo v. Commissioner.

United States Tax Court.

Filed June 24, 1954.

Attorney(s) appearing for the Case

H. E. Russert, Esq., 711 Mahoning Bank Building, Youngstown, Ohio, and Sidney Rigelhaupt, Esq., for the petitioner. Robert E. Johnson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The respondent determined deficiencies in income tax for 1947 and 1949 in the amounts of $53,619.33 and $13,677.13, respectively. The petitioner does not contest certain adjustments made by the respondent. The chief question to be decided is whether a loss sustained by the petitioner in 1949 was attributable to the operation of a trade or business regularly carried on by petitioner.

Findings...

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