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CUNNINGHAM v. COMMISSIONER

Docket Nos. 85421, 87654.

39 T.C. 186 (1962)

LOLA CUNNINGHAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. S. B. INGRAM AND JANE INGRAM, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 22, 1962.

Attorney(s) appearing for the Case

Richard H. Frank, Jr., Esq., for the petitioners.

Robert L. Ackerson, Esq., for the respondent.

ATKINS, Judge:

The respondent determined deficiencies in income tax of petitioner Lola Cunningham and of petitioners S. B. and Jane Ingram for the calendar year 1957 in the amounts of $495.83 and $1,625.02, respectively.

The issue which is common to each of these consolidated cases is whether a partnership consisting of petitioners Lola Cunningham and S. B. Ingram is entitled to deduct in 1957, the last year...

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