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AYLING v. COMMISSIONER

Docket No. 70866.

32 T.C. 704 (1959)

WELLESLEY A. AYLING AND MARY L. AYLING, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 17, 1959.

Attorney(s) appearing for the Case

George D. Strassner, Esq., for the petitioners.

Clarence C. Roby, Esq., for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in income tax and addition to tax as follows:

                                               Addition to tax,
Year                           Deficiency   sec. 294(d), I.R.C. 1939

1954 -----------------------    $855.57             $247.12
1955 -----------------------   3,847.07             -------

The issues for decision are (1) whether...

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