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FRIEND v. COMMISSIONER

Docket No. 72769.

20 T.C.M. 858 (1961)

T.C. Memo. 1961-167

Lee Friend and Wanda S. Friend v. Commissioner.

United States Tax Court.

Filed June 8, 1961.

Attorney(s) appearing for the Case

Mandel M. Einhorn, Esq., for the petitioners. William F. Chapman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

The respondent determined a deficiency in income tax and additions thereto for the taxable year 1954 as follows:

                                   I. R. C. 1939
                             ---------------------------
             I. R. C. 1954     Sec. 294         Sec.
Income Tax   Sec. 6651(a)     (d) (1) (A)    294 (d) (2)
 $8,494.03     $3,350.18       $1,340.07       $804.04
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