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SANITARY FARMS DAIRY, INC. v. COMMISSIONER

Docket Nos. 49511, 51909.

25 T.C. 463 (1955)

SANITARY FARMS DAIRY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. O. CARLYLE AND EMILY A. BROCK, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 14, 1955.

Attorney(s) appearing for the Case

Vincent C. A. Scully, Jr., Esq., and Sidney B. Gambill, Esq., for the petitioners.

George J. Rabil, Esq., for the respondent.

The Commissioner determined a deficiency of $7,304.96 in income tax for 1950 against Sanitary Farms Dairy, Inc., and, for the same year against O. Carlyle Brock and Emily A. Brock, a deficiency of $7,290.72 and an addition under section 294(d)(1)(A) of $729.08 and an addition under section 294(d)(2) of $437.44.

The issue raised by the petitioners is that the Commissioner erred in taxing $15,618.16 as income of the individual petitioners rather than allowing the amount...

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