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PALMIERI v. COMMISSIONER

Docket No. 59147.

27 T.C. 720 (1957)

NAPOLEON PALMIERI, JR., AND NAN M. PALMIERI, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 28, 1957.

Attorney(s) appearing for the Case

Harry L. Cohn, Esq., for the petitioners.

Marion B. Morton, Esq., for the respondent.

This proceeding involves a deficiency in income tax in the amount of $575 for the year 1952.

The sole issue is whether certain rental income from property which petitioner Nan M. Palmieri owned was taxable to her or to her mother who had the use of the property. Respondent conceded the other issue originally raised in the petition, and such concession will be taken into account in a Rule 50 computation.

FINDINGS OF...

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