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WORTH v. COMMISSIONER

Docket No. 78891.

20 T.C.M. 216 (1961)

T.C. Memo. 1961-39

Harry A. Worth and Helen R. Worth v. Commissioner.

United States Tax Court.

Filed February 17, 1961.

Attorney(s) appearing for the Case

E. C. Pommerening, Esq., 231 W. Wisconsin Ave., Milwaukee, Wis., and Glen E. Pommerening, Esq., for the petitioners. William J. Wise, Esq., and James T. Wilkes, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FISHER, Judge:

Respondent determined deficiencies in income tax of petitioners as follows:

                            Addition to
  Year      Deficiency     tax under Sec.
                         6654, I. R. C. 1954

  1955 ....  $3,311.60         $29.15
  1956 ....     909.64           None

The issues involved are:

(1) Whether certain parcels of unimproved real estate sold during...

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