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TOMBARI v. COMMISSIONER

Docket No. 76396.

35 T.C. 250 (1960)

WILLIAM A. AND MARGARET K. TOMBARI, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 10, 1960.

Attorney(s) appearing for the Case

Francis J. Butler, Esq., for the petitioners.

George E. Constable, Esq., for the respondent.

OPINION.

BLACK, Judge:

The Commissioner has determined deficiencies in the income tax of petitioners for the years 1951 and 1952 in the respective amounts of $31,454.21 and $538.70. The only adjustment in issue for 1951 is adjustment "(d) Long-term capital gain $39,322.33" and is explained in the deficiency notice as follows:

(d) It has been determined that the payments received in the year 1951 from...

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