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MARCELLA v. COMMISSIONER

Docket No. 38043.

13 T.C.M. 82 (1954)

Anthony Marcella and Bessie Marcella v. Commissioner.

United States Tax Court.

Entered January 29, 1954.

Attorney(s) appearing for the Case

Joseph A. Hoskins, Esq., and R. E. McGannon, Esq., for the petitioners. R. H. Garrison, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

This proceeding involves a deficiency in income tax for the year 1947 in the amount of $10,635.73 and a fraud penalty in the amount of $5,317.87. The issues are (1) whether petitioners understated their joint income; (2) the long-term capital gain realized from the sale of a piece of real property; and (3) whether any part of the deficiency is due to fraud with intent to evade tax.

Findings...

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