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McCULLOUGH TOOL COMPANY v. COMMISSIONER

Docket No. 66616.

33 T.C. 743 (1960)

McCULLOUGH TOOL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 28, 1960.

Attorney(s) appearing for the Case

Wilson B. Copes, Esq., and James E. Harrington, Esq., for the petitioner.

Richard W. Janes, Esq., and Cyrus Johnson, Esq., for the respondent.

The respondent has determined deficiencies in petitioner's income and excess profits taxes as follows:

Year                                             Amount

1951 ---------------------------------------   $104,690.01
1952 ---------------------------------------     86,898.80

The deficiencies arise from respondent's disallowance of deductions for depreciation of certain patents and disallowance of the inclusion of certain sums as...

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