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BLAKE v. COMMISSIONER

Docket Nos. 82522, 86145.

20 T.C.M. 1606 (1961)

T.C. Memo. 1961-311

C. C. Blake, H. M. Blake and M. J. Orr, Trustees for J. Y. Gooch Co., Inc., a Dissolved Corporation v. Commissioner. Perrine Palmer, Jr., and Clotile Palmer v. Commissioner.

United States Tax Court.

Filed November 14, 1961.

Attorney(s) appearing for the Case

Cyrus A. Neuman, Esq., Pan American Bldg., Miami, Fla., for the petitioners in Docket No. 82522. Julius G. Hirsch, Esq., 29 Broadway, New York, N. Y., and John T. Reges, Esq., for the petitioners in Docket No. 86145. Richard W. Roe, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined the following deficiencies in income tax for the year 1957:

  J. Y. Gooch Co., Inc. ........   $31,200.00
  Perrine Palmer, Jr. and Clotile
    Palmer .....................    44,811.05

The issues are:

1. Whether $60,000 paid by J. Y. Gooch Co., Inc. to Perrine Palmer in 1957 represented compensation paid to Palmer for services rendered to the corporation, or whether...

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