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FRANK H. AYRES & SON v. COMMISSIONER

Docket No. 37033.

13 T.C.M. 952 (1954)

T. C. Memo. 1954-172

Frank H. Ayres & Son v. Commissioner.

United States Tax Court.

Filed October 12, 1954.

Attorney(s) appearing for the Case

Raymond R. Hails, Esq., 412 West Sixth Street, Los Angeles, Calif., and M. B. Hunt, Esq., for the petitioner. Clayton J. Burrell, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

The respondent determined deficiencies in income tax of the petitioner, as follows:

  Fiscal Year Ended               Deficiency

  June 30, 1948 ..............    $11,277.07
  June 30, 1949 ..............      1,227.81
  June 30, 1950 ..............     17,556.68

The question for decision is whether the petitioner was formed or availed of during any of the taxable years ended...

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