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ESTATE OF HARLEY v. COMMISSIONER

Docket No. 62653.

18 T.C.M. 717 (1959)

T.C. Memo. 1959-165

Estate of Frank E. Harley, Deceased, Mabel Harley, Executrix, and Mabel Harley, Individually, Petitioners v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

Filed August 27, 1959.

Attorney(s) appearing for the Case

Frank E. Harley, for the petitioners.

Arthur Pelikow, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TURNER, Judge:

The respondent determined deficiencies in income tax and additions to tax under section 294(d)(2) of the Internal Revenue Code of 1939 against the petitioners as follows:

                                 Addition
  Year              Deficiency    to Tax

  1951 ..........   $  755.00     $ 55.85
  1952 ..........    6,642.40      382.81...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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