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BABCOCK v. COMMISSIONER

Docket No. 55993.

28 T.C. 781 (1957)

FRANK W. BABCOCK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 28, 1957.

Attorney(s) appearing for the Case

Austin Clapp, Esq., for the petitioner.

J. Earl Gardner, Esq., for the respondent.

OPINION.

ATKINS, Judge:

The respondent determined a deficiency in the petitioner's income tax for the calendar year 1949 in the amount of $15,323.09 and an addition thereto under section 293 (a) of the Internal Revenue Code of 1939 in the amount of $992.38. The petitioner challenges only so much of the deficiency and addition as arises out of the respondent's determination that the petitioner realized a recognizable gain as the result of condemnation...

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