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ZONGKER v. COMMISSIONER

Docket No. 82847.

39 T.C. 1046 (1963)

E. J. ZONGKER AND CHARLEEN ZONGKER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 26, 1963.

Attorney(s) appearing for the Case

Wayne Coulson, Esq., and Willard B. Thompson, Esq., for the petitioners.

Claude R. Sanders, Esq., for the respondent.

FISHER, Judge:

Respondent has determined deficiencies in petitioners' income tax and liability for additions to tax under section 294(d)(1)(A), section 294(d)(2), Code of 1939, and section 6651(a), Code of 1954, for the calendar years 1953 and 1955 as follows:

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