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MELDON v. COMMISSIONER

Docket No. 30427.

13 T.C.M. 765 (1954)

T. C. Memo. 1954-120

James L. Meldon v. Commissioner.

United States Tax Court.

Filed August 12, 1954.

Attorney(s) appearing for the Case

Enoch C. Filer, Esq., 1005 Ariel Building, Erie, Pa., for the petitioner. Fortescue W. Hopkins, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

This proceeding involves deficiencies in income tax for the years 1945 and 1946 and a fraud penalty for 1945 as follows:

  Year            Income Tax       Penalty

  1945 ..........  $203,878.04    $101,939.02
  1946 ..........     7,911.37     .........

The issues presented are:

1. Whether the conceded amount of $226,961.54 received by petitioner...

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