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LIVESLEY v. COMMISSIONER

Docket Nos. 66512, 66513.

19 T.C.M. 133 (1960)

T.C. Memo. 1960-24

Helen M. Livesley v. Commissioner. Phil A. Livesley v. Commissioner.

United States Tax Court.

Filed February 23, 1960.

Attorney(s) appearing for the Case

Morris J. Galen, Esq., for the petitioners. John D. Picco, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

The respondent has determined the following deficiencies in the petitioners' Federal income tax:

  Fiscal Year Ended        Deficiency

  July 31, 1952 .........  $12,348.01
  July 31, 1953 .........    1,159.53

The issues, as framed by the parties, are:

1. Whether the partnership owned and operated by the petitioners, or Phil A. Livesley in his individual capacity...

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