RIZZO v. COMMISSIONER

Docket No. 70699.

20 T.C.M. 1379 (1961)

T.C. Memo. 1961-265

Joseph Rizzo v. Commissioner.

United States Tax Court.

Filed September 21, 1961.


Attorney(s) appearing for the Case

Morton Silfen, Esq., for the petitioner. Edward H. Hance, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies in income tax due from petitioner for the taxable years 1951, 1952, and 1953 in the amounts of $349.92, $2,865.77, and $110.16, respectively, and an addition to tax under section 294(d)(2) of the Internal Revenue Code of 1939 for the taxable year 1951 in the amount of $206.10.

The issues for decision are:

(1) Whether petitioner is entitled to deduct...

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