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SPARKS v. COMMISSIONER

Docket No. 72109.

19 T.C.M. 807 (1960)

T.C. Memo. 1960-154

Jerrell Monroe Sparks v. Commissioner.

United States Tax Court.

Filed July 18, 1960.

Attorney(s) appearing for the Case

Harry I. Goodley, Esq., 6416 Lindenhurst Avenue, Los Angeles, Calif., for the petitioner. Edward M. Fox, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

This proceeding involves a deficiency in income tax and an addition thereto for the taxable year 1952 in the amounts set forth below:

                                  Addition to Tax
                                    Sec. 291(a),
  Year              Deficiency     I. R. C. 1939

  1952.............    $496            $124

The issues for decision are: (1) Whether petitioner...

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