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LLEWELLYN v. COMMISSIONER

Docket No. 69807.

19 T.C.M. 1023 (1960)

T.C. Memo. 1960-197

Maxwell B. Llewellyn and Gertrude Llewellyn v. Commissioner.

United States Tax Court.

Filed September 22, 1960.

Attorney(s) appearing for the Case

Hiram M. Nowlan, Esq., 17 North Franklin Street, Janesville, Wis., for the petitioners. Rex A. Guest, Esq., for the respondent.

Memorandum Opinion

FISHER, Judge:

Respondent determined deficiencies in income tax and additions to tax of the petitioners as follows:

                                  Addition
                                 to the Tax
                               Sec. 294(d) (2),
  Year             Income Tax   I. R. C. 1939

  1953............   $1,981.18     ......
  1954............    4,012.63     $217.57

The issues presented are ...

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