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NATIONAL CLOTHING CO. OF ROCHESTER, INC. v. COMMISSIONER

Docket Nos. 49334, 49397.

23 T.C. 944 (1955)

NATIONAL CLOTHING CO. OF ROCHESTER, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. WILLARD D. AVERY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 28, 1955.

Attorney(s) appearing for the Case

Dean P. Kimball, Esq., for the petitioners.

A. W. Dickinson, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax of $20,704.16 and $27,226.75 against the corporation for its fiscal years ended January 31, 1949 and 1950, and he also determined a deficiency in income tax against Avery of $8,908.13 for the calendar year 1949. The only issue for decision is whether certain amounts represented additional compensation from the corporation to employees or whether they represented a part...

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