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VOGEL v. COMMISSIONER

Docket No. 48047.

14 T.C.M. 275 (1955)

T.C. Memo. 1955-83

Edward J. Vogel and Mitzi Germaine Vogel v. Commissioner.

United States Tax Court.

Filed April 12, 1955.

Attorney(s) appearing for the Case

Leonard J. Schwartz, Esq., Bankers Securities Building, Philadelphia, Pa., for the petitioners. Stephen P. Cadden, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

Respondent determined deficiencies in the income tax of petitioners and additions to tax under section 293(b) of the Internal Revenue Code of 1939 as follows:

   Year             Deficiency    Addition to tax

   1946 .........    $50,671.46      $25,335.73
   1947 .........     17,622.58        8,811.29

Several issues were raised by the pleadings but all of them have been...

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