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MARSHMAN v. COMMISSIONER

Docket No. 61457.

17 T.C.M. 864 (1958)

T.C. Memo. 1958-174

Homer H. and Ina Mae Marshman v. Commissioner.

United States Tax Court.

Filed September 19, 1958.

Attorney(s) appearing for the Case

William F. Snyder, Esq., for the petitioners. William O. Allen, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined deficiencies in the petitioners' income tax and addition to tax, as follows:

                                     Addition
                                   to Tax Under
  Year              Deficiency    Sec. 294(d)(2)

  1952 ........... $ 7,620.63       ........
  1953 ...........  24,555.70      $2,106.22

The issue in this case is whether petitioner...

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