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SMITH v. COMMISSIONER

Docket Nos. 92546, 4041-62.

22 T.C.M. 1146 (1963)

T.C. Memo. 1963-227

Harold F. Smith, et ux. v. Commissioner.

United States Tax Court.

Filed August 23, 1963.

Attorney(s) appearing for the Case

R. M. Ginsberg, 1603 Kirby Bldg., Dallas, Tex., for the petitioners. James F. Hart for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiencies in the income taxes of petitioners for the years and in the amounts as follows:

  Year               Deficiency

  1958 ............. $16,204.11
  1959 .............   6,102.95
  1960 .............     388.92

Petitioners have conceded some adjustments raised in the statutory notice of deficiency, thus leaving two issues for decision: (1)...

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