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HOWARD v. COMMISSIONER

Docket No. 55034.

15 T.C.M. 1152 (1956)

T.C. Memo. 1956-219

Ray Howard and Mable B. Howard v. Commissioner.

United States Tax Court.

Filed September 27, 1956.

Attorney(s) appearing for the Case

Ray Howard, Esq., Pershing Square Building, Los Angeles, Calif., for the petitioners. Mark Townsend, Esq., for the respondent.

Memorandum Opinion

RICE, Judge:

This proceeding involves a deficiency in income tax for 1950 in the amount of $1,941.26.

The issues to be determined are: (1) Whether all or any part of certain fees received by petitioner in 1950 for legal services performed by him were taxable under the provisions of section 107(a) of the 1939 Code; and (2) whether petitioners' payment of a deficiency assessment for the...

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