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HERBERT v. COMMISSIONER

Docket No. 61138.

30 T.C. 26 (1958)

ELIZABETH HERBERT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 15, 1958.

Attorney(s) appearing for the Case

John Holt Myers, Esq., for the petitioner.

William Schwerdtfeger, Esq., for the respondent.

FINDINGS OF FACT AND OPINION.

KERN, Judge:

Respondent has determined deficiencies in petitioner's Federal income taxes for the years 1952 and 1953 in the respective amounts of $5,762.62 and $7,806.09. These deficiencies result from respondent's determination that petitioner (a British subject) "[has] been and [is] engaged in a trade or business through a permanent establishment in the United States and, therefore...

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