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PERKINS v. COMMISSIONER

Docket No. 78070.

36 T.C. 313 (1961)

JOHN HAMILTON PERKINS AND VIRGINIA M. PERKINS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 19, 1961.

Attorney(s) appearing for the Case

Walter L. Mims, Esq., and Sam C. Pointer, Jr., Esq., for the petitioners.

Frederick T. Carney, Esq., for the respondent.

PIERCE, Judge:

Respondent determined a deficiency in the petitioners' income tax for the year 1951, in the amount of $26,666.78.

Said deficiency was determined through application of sections 1311 through 1315 of the 1954 Code (pertaining to mitigation of effect of limitations)—which sections make provision for the correction, in certain situations, of the effect of an erroneous treatment of an item of...

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