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ESTATE OF DAY v. COMMISSIONER

Docket Nos. 45520, 45521.

14 T.C.M. 430 (1955)

T.C. Memo. 1955-118

Estate of Ralph E. Day, Deceased, Ernestine B. Day Kirkpatrick, Executrix v. Commissioner. Ernestine B. Day Kirkpatrick, Formerly Ernestine B. Day v. Commissioner.

United States Tax Court.

Filed May 12, 1955.

Attorney(s) appearing for the Case

Robert Ash, Esq., Munsey Building, Washington, D. C., and Carl F. Bauersfeld, Esq., for the petitioners. A. F. Barone, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income taxes as follows:

  Docket No.        Year            Deficiencies

  45520.....  1-1-46 to 5-2-46....   $16,964.77
  45521.....        1946      ....    22,688.18

The question to be decided is the extent, if any, to which the purchase price paid by petitioners for certain citrus groves...

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